@ThomasBeyer when using this strategy, do you (1) sell shares or (2) transfer assets to subsidiary, then sell that subsidiary?
(1) In the case of the share sale, you end up with a capital gain on the ACB of the shares.
(2) If transfer of real estate is made under subsection 85(1), then land and property is transferred on a tax-deferred basis. The subsidiary inherits the ACB of land and UCC of depreciable property. But, you end up with a capital gain tax at the corporate level to the parent, then a withholding tax on dividend for the final distribution.
Obviously, partly a math question (we are working through one now). But which route do you prefer?