Income Tax Act — I-3.3 107.4
 (2) For the purpose of paragraph (1)(a), (a) except where paragraph (b) applies, where a trust (in this paragraph and subsection (2.1) referred to as the “transferor trust”), in a period that does not exceed one day, disposes of one or more properties in the period to one or more other trusts, there is deemed to be no resulting change in the beneficial ownership of those properties if (i) the transferor trust receives no consideration for the disposition, and (ii) as a consequence of the disposition, the value of each beneficiary’s beneficial ownership at the beginning of the period under the transferor trust in each particular property of the transferor trust (or group of two or more properties of the transferor trust that are identical to each other) is the same as the value of the beneficiary’s beneficial ownership at the end of the period under the transferor trust and the other trust or trusts in each particular property (or in property that was immediately before the disposition included in the group of identical properties referred to above); and (b) where a trust (in this paragraph referred to as the “transferor”) governed by an arrangement that is a FHSA, a registered retirement savings plan or a registered retirement income fund transfers a property to a trust (in this paragraph referred to as the “transferee”) governed by such an arrangement, the transfer is deemed not to result in a change in the beneficial ownership of the property if the annuitant or holder of the arrangement that governs the transferor is also the annuitant or holder of the arrangement that governs the transferee. Fractional interests (2.1) For the purpose of applying paragraph (2)(a) in respect of a transfer by a transferor trust of property that includes a share and money, the other trust or trusts referred to in that paragraph may receive, in lieu of a transfer of a fractional interest in a share that would otherwise be required, a disproportionate amount of money or interest in the share (the value of which does not exceed the lesser of $200 and the fair market value of the fractional interest). Tax consequences of qualifying dispositions (3) Where at a particular time there is a qualifying disposition of a property by a person or partnership (in this subsection referred to as the “transferor”) to a trust (in this subsection referred to as the “transferee trust”), (a) the transferor’s proceeds of disposition of the property are deemed to be (i) where the transferor so elects in writing and files the election with the Minister on or before the transferor’s filing-due date for its taxation year that includes the particular time, or at any later time that is acceptable to the Minister, the amount specified in the election that is not less than the cost amount to the transferor of the property immediately before the particular time and not more than the fair market value of the property at the particular time, and (ii) in any other case, the cost amount to the transferor of the property immediately before the particular time; (b) the transferee trust’s cost of the property is deemed to be the amount, if any, by which (i) the proceeds determined under paragraph (a) in respect of the qualifying disposition exceed (ii) the amount by which the transferor’s loss otherwise determined from the qualifying disposition would be reduced because of subsection 100(4), paragraph 107(1)(c) or (d) or any of subsections 112(3) to (4.2), if the proceeds determined under paragraph (a) were equal to the fair market value of the property at the particular time; (c) [Repealed, 2005, c. 30, s. 4] (d) if the property was depreciable property of a prescribed class of the transferor and its capital cost to the transferor exceeds the cost at which the transferee trust is deemed by this subsection to have acquired the property, for the purposes of sections 13 and 20 and any regulations made for the purpose of paragraph 20(1)(a), (i) the capital cost of the property to the