In 2017 STEP Roundtable Q.7, 2017-0693421C6, CRA stated that safe income of a corporation owned by the deceased did not flow through to his estate. Would this apply if the shares transferred on a rollover basis under s. 70(6) to the estate?
CRA indicated that the basis for the referenced position was that the safe income was crystalized in the ACB of the shares that were now held by the estate. However, where the shares were disposed of at their adjusted cost base because of the s. 70(6) rollover, the safe income that could reasonably be considered to contribute to the accrued gain on those shares would flow through to the estate.