Income Tax Act — I-3.3 (a)
disposition of any property, except as expressly otherwise provided, includes (a) any transaction or event entitling a taxpayer to proceeds of disposition of the property, (b) any transaction or event by which, (i) where the property is a share, bond, debenture, note, certificate, mortgage, hypothecary claim, agreement of sale or similar property, or interest, or for civil law a right, in it, the property is in whole or in part redeemed, acquired or cancelled, (ii) where the property is a debt or any other right to receive an amount, the debt or other right is settled or cancelled, (iii) where the property is a share, the share is converted because of an amalgamation or merger, (iv) where the property is an option to acquire or dispose of property, the option expires, and (v) a trust, that can reasonably be considered to act as agent for all the beneficiaries under the trust with respect to all dealings with all of the trust’s property (unless the trust is described in any of paragraphs (a) to (e.1) of the definition trust in subsection 108(1)), ceases to act as agent for a beneficiary under the trust with respect to any dealing with any of the trust’s property, (b.1) where the property is an interest in a life insurance policy, a disposition within the meaning of section 148, (c) any transfer of the property to a trust or, where the property is property of a trust, any transfer of the property to any beneficiary under the trust, except as provided by paragraph (f) or (k), and (d) where the property is, or is part of, a taxpayer’s capital interest in a trust, except as provided by paragraph (h) or (i), a payment made after 1999 to the taxpayer from the trust that can reasonably be considered to have been made because of the taxpayer’s capital interest in the trust, but does not include (e) any transfer of the property as a consequence of which there is no change in the beneficial ownership of the property, except where the transfer is (i) from a person or a partnership to a trust for the benefit of the person or the partnership, (ii) from a trust to a beneficiary under the trust, or (iii) from one trust maintained for the benefit of one or more beneficiaries under the trust to another trust maintained for the benefit of the same beneficiaries, (f) any transfer of the property as a consequence of which there is no change in the beneficial ownership of the property, where (i) the transferor and the transferee are trusts that are, at the time of the transfer, resident in Canada, (ii) [Repealed, 2013, c. 34, s. 358] (iii) the transferee does not receive the property in satisfaction of the transferee’s right as a beneficiary under the transferor trust, (iv) the transferee held no property immediately before the transfer (other than property the cost of which is not included, for the purposes of this Act, in computing a balance of undeducted outlays, expenses or other amounts in respect of the transferee), (v) the transferee does not file a written election with the Minister on or before the filing-due date for its taxation year in which the transfer is made (or on such later date as is acceptable to the Minister) that this paragraph not apply, (vi) if the transferor is an amateur athlete trust, a cemetery care trust, an employee trust, a trust deemed by subsection 143(1) to exist in respect of a congregation that is a constituent part of a religious organization, a related segregated fund trust (in this paragraph having the meaning assigned by section 138.1), a trust described in paragraph 149(1)(o.4) or a trust governed by an eligible funeral arrangement, an employees profit sharing plan, a FHSA, a registered disability savings plan, a registered education savings plan, a registered supplementary unemployment benefit plan or a TFSA, the transferee is the same type of trust, and (vii) the transfer results, or is part of a series of transactions or events that results, in the transferor ceasing to exist and, immediately before the t