Joe Solder is a resident of the United States and owns 25% of the shares of a Canadian-controlled private corporation with operations in Waterloo. The value of the shares is $150,000. He was issued the shares for $300 on incorporation in 1996. Joe’s brother, Samuel, owns 75% of the shares of the company. Samuel lives and works in Waterloo. Samuel has offered to purchase Joe’s shares at fair market value on April 1, 2016.

REQUIRED

Part A—Assuming the shares are not treaty protected:

(1) If the date is January 15, 2016, what compliance requirements should be met by Joe?

(2) If the date is April 20, 2016 and the transaction has already occurred, what compliance requirements should be met by Joe and Samuel?

Part B—Answer the above assuming the shares are treaty protected.