Income Tax Act — I-3.3 110.6
 a corporation to a particular person or partnership shall be deemed to have been owned immediately before their issue by a person who was not related to the particular person or partnership unless the shares were issued (i) as consideration for other shares, (ii) as part of a transaction or series of transactions in which the person or partnership disposed of property to the corporation that consisted of (A) all or substantially all the assets used in an active business carried on by that person or the members of that partnership, or (B) an interest in a partnership all or substantially all the assets of which were used in an active business carried on by the members of the partnership, or (iii) as payment of a stock dividend; and (g) where, immediately before the death of an individual, or, in the case of a deemed transfer under subsection 248(23), immediately before the time that is immediately before the death of an individual, a share would, but for paragraph (a) of the definition qualified small business corporation share in subsection 110.6(1), be a qualified small business corporation share of the individual, the share shall be deemed to be a qualified small business corporation share of the individual if it was a qualified small business corporation share of the individual at any time in the 12-month period immediately preceding the death of the individual. Value of assets of corporations (15) For the purposes of the definitions qualified small business corporation share and share of the capital stock of a family farm or fishing corporation in subsection (1), the definition share of the capital stock of a family farm or fishing corporation in subsection 70(10) and the definition small business corporation in subsection 248(1), (a) where a person (in this subsection referred to as the “insured”), whose life was insured under an insurance policy owned by a particular corporation, owned shares of the capital stock (in this subsection referred to as the “subject shares”) of the particular corporation, any corporation connected with the particular corporation or with which the particular corporation is connected or any corporation connected with any such corporation or with which any such corporation is connected (within the meaning of subsection 186(4) on the assumption that the corporation referred to in this subsection was a payer corporation within the meaning of that subsection), (i) the fair market value of the life insurance policy shall, at any time before the death of the insured, be deemed to be its cash surrender value (within the meaning assigned by subsection 148(9)) at that time, and (ii) the total fair market value of assets — other than assets described in any of subparagraphs (c)(i) to (iii) of the definition qualified small business corporation share in subsection (1), any of subparagraphs (a)(i) to (iii) of the definition share of the capital stock of a family farm or fishing corporation in subsection (1) or any of paragraphs (a) to (c) of the definition small business corporation in subsection 248(1), as the case may be — of any of those corporations that are (A) the proceeds, the right to receive the proceeds or attributable to the proceeds, of the life insurance policy of which the particular corporation was a beneficiary, and (B) used, directly or indirectly, within the 24-month period beginning at the time of the death of the insured or, where written application therefor is made by the particular corporation within that period, within such longer period as the Minister considers reasonable in the circumstances, to redeem, acquire or cancel the subject shares owned by the insured immediately before the death of the insured, not in excess of the fair market value of the assets immediately after the death of the insured, shall, until the later of (C) the redemption, acquisition or cancellation, and (D) the day that is 60 days after the payment of the proceeds under the policy, be deemed not to exceed