43. There shall be an exemption from the payment of duties, in the following cases, provided the deed of transfer mentions the fact that:(a) the transfer is made by a transferor who is a physical person to a transferee who is a corporation not resident in Canada of which 90 per cent of the issued shares of its capital stock to which are attached full voting rights are owned by such transferor immediately after the transfer; or
(b) the transfer is made by a transferor that is a corporation to a physical person not resident in Canada, if such person is, immediately before the transfer, the owner of at least 90 per cent of the issued shares to which are attached full voting rights, of the capital stock of the transferor.