Tax effective structures for Canadian search funds

I've been thinking about how best to structure both the fund and the acquisition for tax purposes for investors and the searcher.  Circumstances will be different based on the needs of parties involved and the type of company purchased and should always involve an independent tax specialist. Here are some of my thoughts:

I assume that the searcher will have unused lifetime capital gains exemption and the company purchased will qualify as a QSBC. I also assume that investors will have other income during the search phase and will benefit from recording partnership expenses.