CRA recognizes that a transfer for nominal consideration can be a gift

When asked whether a transfer of an immovable for $1 to a non-arm’s length person can be a gift, CRA responded that, in the absence of sham "the genuine legal relations must be respected in tax matters" – which sounds generally favourable. Note also that in ITTN No. 44, CRA stated, apparently based on s. 69(1)(c) re "gifts," that "a corporation that receives property from its shareholder for no consideration has a cost basis for that property equal to its FMV."

Neal Armstrong. Summary of 10 October 2014 APFF Roundtable, Q. 8, 2014-0538621C6 F under s. 69(1)(c).