John has owned all of the shares of Corporation A and Corporation B since their inception. In the current year, John had Corporation A transfer, on a tax-deferred basis, property used in its business to Corporation B. The reason for the transfer is to enable Corporation B to apply the income earned on the transferred assets against its non-capital losses.
Will the GAAR in ITA 245(2) apply to disallow the tax benefit? Income tax reference: ITA 245(1),(2),(3),(4); IC 88-2.