CRA considers that s. 7 can apply to a bona fide sale to an employee of a share investment in a subsidiary

CRA considers that where Holdco sells a portion of its investment in the shares of Opco to an Opco employee at a sale price that is intended to represent fair market value, the s. 7 rules will apply, so that if CRA treats the fair market value as being higher, it will compute a s. 7 benefit.

Neal Armstrong.  Summary of 1 June 2015 T.I. 2015-0581311E5 under s. 7(1)(a).