CRA indicated that an individual who donated land to an unrelated couple could be regarded as not dealing with them at arm’s length (stating that “the CRA generally assumes that two parties are not dealing at arm's length in a gift situation”), in which case, the transaction might be viewed as an inter vivos gift (so that the donees had full cost under s. 69)(1)(c)) or as a sale for $1 consideration (in which event, there would be no such cost to the donees). CRA stated:
[T]he terms used in the deed of gift, i.e., "the gift of real property" or "the sale for $1 of real property", would not have the effect of automatically limiting the application of the rules in subsection 69(1).