Transfer of SPV shares to a business trust treated as non-transfer; transferee units inherit original cost and holding period. A transfer of SPV shares to a business trust in exchange for units is a transaction not regarded as transfer. The cost of acquisition of the allotted units in the hands of the SPV shareholder equals the cost at which the shareholder acquired the SPV shares, and the period for which the shareholder held the SPV shares is included in the holding period of the transferee units.