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Susanne has been approached by an investor about acquiring her shares of Sparrow Inc, which she owns 100% of. The structure of the proposed deal

Susanne has been approached by an investor about acquiring her shares of Sparrow Inc, which she owns 100% of. The structure of the proposed deal is that the shares of Sparrow Inc. will be transferred to Excelsior Corp, and Susanne will receive shares of Excelsior Corp as consideration. Afterwards she will own 5% of Excelsior. The investor assured Susanne that she should not have to pay any tax as part of the deal, and they will not need to file any elections. Under what section of the income tax act might this transaction be completed under?

Section 86

Section 85

Section 87

Section 85.1

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