Would a taxpayer be entitled to the s. 110(1)(d.01) deduction by virtue of s. 110(2.1) if he directed the approved broker to dispose of his shares acquired on exercise and donates the proceeds to a qualified donee personally instead of directing the broker to do so? What is the meaning of “immediately” in s. 110(2.1). CRA responded:
[I]f the broker or dealer pays the proceeds of disposition directly to the taxpayer who then donates all or some of the proceeds… the requirements of subsection 110(2.1) are not met and thus a deduction under paragraph 110(1)(d.01) would not be available. …
“[I]mmediately” in the phrase “to immediately dispose of the security and pay all or a portion of the proceeds” in subsection 110(2.1)…refers to both the disposition of the security and the payment of the proceeds to the qualified donee.