19 January 2017 External T.I. 2015-0576751E5 F - Trust, Disposition of depreciable property, Assumption -- summary under Paragraph 251(1)(c)

CRA agreed that the ½ step-up rule in s. 13(7)(e) does not apply to a deemed disposition under s. 104(5) given that the trust is not related to itself and does not otherwise not deal at arm’s length with itself.