2016 Ruling 2016-0635051R3 - rollout property to beneficiary non-resident trust -- summary under Subsection 107(4.1)

CRA ruled that the s. 107(2) rollover applied (and s. 245(2) did not apply) to the distribution by a non-resident trust, to which s. 94(8.2) (or s. 75(2)) no longer applied because its settlor had been dissolved, of Canadian rental property to its sole beneficiary, which was a (presumably non-resident) corporation related to the Canadian-resident lessee of the property. No representation was made that the settlor was not wound-up to permit accessing the rollover.