22 March 2016 Internal T.I. 2013-0506561I7 - Property acquired on a return of capital -- summary under Adjusted Cost Base

CRA considered that property contributed for no consideration to a corporation by its shareholder, or received by a Canadian corporate shareholder from its wholly-owned foreign affiliate on a return of capital (or other upstream transfer), generally will have a cost to the transferee equal to the property’s fair market value.