The general anti$-$avoidance provision, GAAR, is most likely to apply to which one of the following transactions?

As part of an estate freeze, Bill had a trust for his adult children acquire $80\%$ of the common shares of B Ltd$.$ Until then, Bill had owned all the shares of B Ltd$.,$ a successful grocery retail outlet. Each year B$.$Ltd$.$ pays dividends to the trust which are paid to the children, all between the ages of $22$ and $28.$ As university students, they have no other income and all work part time for the grocery store during the summer.

Sam transferred his unincorporated pizza business, on a tax$-$deferred basis, to a corporation, for the sole purpose of reducing tax by claiming the small business deduction.

Paul gave his son a gift of $$10,000$ and the son invested it in dividend$-$paying shares. His son does not pay tax on the dividend income as he is a $19-$year$-$old student with little other income. Paul will celebrate his $65$th birthday two years after his son graduates. It is anticipated that Paul will receive a birthday gift of $$10,000$ from his son at that time.

Mary owns all the shares of M Ltd$.,$ a CCPC that carries on an active business. For M Ltd$.\text{'}$s taxation year ended june $30,2024,$ Mary accrued herself a bonus of $$700,000$ that reduced M Ltd$.\text{'}$s taxable income to $$300,000.$