See Also
Davidson Estate v. The Queen, 96 DTC 1652 (TCC)
The estate of a deceased taxpayer (which was deemed by s. 248 to be a person) was found to be dealing at arm's length with the taxpayer's surviving wife with respect to a transfer of shares from the estate to her, given that two of the three executors were unrelated to the deceased taxpayer, and the estate had complete discretion as to whether it would sell the shares or transfer them to the wife in specie. Accordingly, ITAR 26(5) did not apply in computing the adjusted cost base of the shares to the wife's estate following her death.
Administrative Policy
8 November 1994 Memorandum 942638 (C.T.O. "Transfer of Pre-1972 Property to a Trust")
The words "or events" were added in ITAR 26(5) for greater certainty in order to confirm that the provision applied to bequests.