CRA provides favourable interpretation on the ability of a Newco (which may take a while to get going) to make an ETA s. 156 nil consideration election

A member of a closely-related corporate group generally will be a "qualifying member," so as to be able to make a nil consideration election with other qualifying group members under ETA s. 156 if (under (c)(i) if the "qualifying member" definition") substantially all of its property, other than financial instruments or property with only a nominal value ("disregarded property"), has been acquired for consumption, use or supply exclusively in the course of its activities ("commercial acquisitions").  However, if it has no property other than disregarded property, it nonetheless may qualify under (c)(iii) of the "qualifying member" definition if "it is reasonable to expect" that it will be making taxable supplies "throughout" the following 12 months, substantially all of which will be taxable supplies, and that substantially all of its property acquisitions (other than of disregarded property) within those 12 months will be commercial acquisitions.

CRA has issued an interpretation which, reading between the lines, seems to reflect a relaxed interpretation of "throughout" – and notes that if, in fact, the mooted qualifying member has any commercial acquisitions during the 12-month period, it generally will thereupon qualify under the regular test in (c)(i).

Neal Armstrong.  Summary of 14 January 2015 Interpretation 165076 under ETA s. 156(1) – qualifying member.