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The third buy-sell arrangement discussed is the share redemption agreement, noted as the most complex of the three. The tutorial emphasizes key provisions of the Income Tax Act, which may not be immediately clear. In this scenario, Jill has insurance owned corporately, and upon her death, the benefit is paid to the corporation. While a capital dividend account can be beneficial, a share redemption agreement can function without it. Upon Jill's death, Section 70 of the Income Tax Act triggers a deemed disposition of her shares, resulting in a $1,000,000 capital gain on her tax return, potentially offset by the lifetime capital gains exemption. However, the share redemption agreement remains effective regardless of whether this exemption is available.
