If a Holdco’s sole asset is shares of an Opco, and the Opco holds 60% Canadian operating assets and 40% passive investments, would the Opco shares qualify as eligible assets for QSBC purposes at the Holdco level, since more than 50% of the Opco’s FMV is attributable to assets used in an active business?
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The 50% test is for the 2-year period before the sale. At the time of the sale it has to be 90% active assets.