[21]  The Tax Court found that the object, spirit and purpose of section 84.1 was correctly identified in Descarries v. Canada, 2014 TCC 75 (CanLII), [2014] D.T.C. 1081: an anti-avoidance rule “to prevent taxpayers from performing transactions whose goal is to strip a corporation of its surpluses tax-free through the use of a tax-exempt margin or a capital gain exemption.” (reasons, paragraph 67).