In finding that income from shares acquired by a minor child from money received as a consequence of the death of a parent was not excluded under para. (a), CRA stated:
[I]f Parliament wished to exempt from the attribution rules substitute or replacement property when applying subsection 120.4(1), it would have done so expressly. For example, in subsection 74.1(1), Parliament wrote "...the income or loss … of that person for a taxation year from the property or from property substituted therefor .....". …
Furthermore … the definition of substituted property in subsection 248(5) … [only] applies to provisions of the Act that contain the words "substituted property".
In addition, the shares, as contrasted to the money, were not acquired “as a consequence of the death.”