Patricia is a sole shareholder of P-Ltd. P-Ltd is a Canadian-Controlled Private Corporation with investments in numerous Canadian public companies.

Patricias husband, John, owns all of the shares of J-Ltd., a Canadian-controlled private corporation, with excess cash.

They have decided to have J-Ltd. purchase the shares of P-Ltd. in order to provide Patricia with the cash required to take advantage of another investment opportunity.

The shares of P-Ltd. are currently worth $450,000 and have a PUC and ACB of $50,000. The plan is for J-Ltd. to pay Patricia $450,000 in cash for the P-Ltd. shares.

Patricia never claimed life-time capital gain deduction previously and she was hoping to utilize this time and pay not tax.

Determine the tax consequences for Patricia.