CRA indicates that the prohibition against multiple use of the intergenerational transfer rules doe not apply to simultaneous transfers

One of the “intergenerational transfer” rule requirements, in s. 84.1(2.31)(a) or (2.32)(a), is that a previous inter-generational exception to s. 84.1 has not previously been sought. CRA was asked to address the situation where a parent, who has not previously sought out the intergenerational exception, simultaneously disposes of subject shares to two separate purchaser corporations, each wholly-owned by an adult child. CRA indicated that the s. 84.1(2.31)(a) or (2.32)(a) exception could be met on the basis that the two (or multiple) dispositions occur at the same time as part of the same genuine intergenerational transfer.

Neal Armstrong. Summary of 3 December 2024 CTF Roundtable, Q.10 under s. 84.1(2.31)(a).