Miss Sarah Cole owns 100 percent of the outstanding shares of Cole Inc., a qualified small business corporation. The shares have a PUC and an adjusted cost base of $125,000 and a fair market value of $767,000. The company has no balance in its GRIP account. On February 1, 2020, Miss Cole uses ITA 85(1) to transfer these shares to Sarahs Holdings Ltd. at an elected value of $767,000. As consideration, she receives a note for $450,000 and preferred shares with a fair market value and a legal stated capital of $317,000. Miss Cole owns all of the shares of Sarahs Holdings Ltd. and has never made use of her lifetime capital gains deduction. What are the tax consequences of this transaction to Miss Cole?