Income Tax Act — I-3.3 248
 or event, the property was deemed to be taxable Canadian property of the particular trust by any of paragraphs 51(1)(f), 85(1)(i) and 85.1(1)(a), subsection 85.1(5), paragraph 85.1(8)(b), subsections 87(4) and (5) and paragraphs 97(2)(c) and 107(3.1)(d), the property is also deemed to be, at any time that is within 60 months after the transaction or event, taxable Canadian property of the other trust. Trusts to ensure obligations fulfilled (25.2) Except for the purpose of this subsection, where at any time property is transferred to a trust in circumstances to which paragraph (k) of the definition disposition in subsection (1) applies, the trust is deemed to deal with the property as agent for the transferor throughout the period that begins at the time of the transfer and ends at the time of the first change after that time in the beneficial ownership of the property. Cost of trust interest (25.3) The cost to a taxpayer of a particular unit of a trust is deemed to be equal to the amount described in paragraph (a) where (a) the trust issues the particular unit to the taxpayer directly in satisfaction of a right to enforce payment of an amount by the trust in respect of the taxpayer’s capital interest in the trust; (b) at the time that the particular unit is issued, the trust is neither a personal trust nor a trust prescribed for the purpose of subsection 107(2); and (c) either (i) the particular unit is capital property and the amount is not proceeds of disposition of a capital interest in the trust, or (ii) the particular unit is not capital property and subparagraph 53(2)(h)(i.1) does not apply in respect of the amount described in paragraph (a) but would so apply if that subparagraph were read without reference to clauses 53(2)(h)(i.1)(A) and (B). Where acquisition by another of right to enforce (25.4) If at a particular time a taxpayer’s capital interest in a trust includes a right to enforce payment of an amount by the trust, the amount shall be added at the particular time to the cost otherwise determined to the taxpayer of the capital interest where (a) immediately after the particular time there is a disposition by the taxpayer of the capital interest; (b) as a consequence of the disposition, the right to enforce payment of the amount is acquired by another person or partnership; and (c) if the right to enforce payment of the amount had been satisfied by a payment to the taxpayer by the trust, there would have been no disposition of that right for the purposes of this Act because of the application of paragraph (i) of the definition disposition in subsection (1). Debt obligations (26) For greater certainty, where at any time a person or partnership (in this subsection referred to as the “debtor”) becomes liable to repay money borrowed by the debtor or becomes liable to pay an amount (other than interest) (a) as consideration for any property acquired by the debtor or services rendered to the debtor, or (b) that is deductible in computing the debtor’s income, for the purposes of applying the provisions of this Act relating to the treatment of the debtor in respect of the liability, the liability shall be considered to be an obligation, issued at that time by the debtor, that has a principal amount at that time equal to the amount of the liability at that time. Parts of debt obligations (27) For greater certainty, (a) unless the context requires otherwise, an obligation issued by a debtor includes any part of a larger obligation that was issued by the debtor; (b) the principal amount of that part shall be considered to be the portion of the principal amount of that larger obligation that relates to that part; and (c) the amount for which that part was issued shall be considered to be the portion of the amount for which that larger obligation was issued that relates to that part. Limitation respecting inclusions, deductions and tax credits (28) Unless a contrary intention is evident, no provision of this Act shall be rea