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 s. 120.4(1) – excluded amount - para. (a), CRA stated:
[W]e do not believe that the definition of substituted property in subsection 248(5) applies for the purposes of subsection 120.4(1). That is consistent with Interpretation F2004-0101701E5 which concluded that the definition of substituted property in subsection 248(5) applies to provisions of the Act that contain the words "substituted property".