15 November 2006 External T.I. 2004-0083461E5 F - Feb. 2004 Proposals - Paragraph 85(1)(d.11) -- summary under Paragraph 85(1)(d.11)

CRA noted that the question as to whether the application rule regarding s. 85(1)(d.11) (that it applied in respect of dispositions occurring after December 20, 2002) referred to the initial transfer of the eligible capital property by the taxpayer to the taxable Canadian corporation under s. 85(1) or to the subsequent sale of ECP by that corporation, was now addressed by s. 86(4) of the Notice of Ways and Means Motion tabled on November 9, 2006.