29 May 2018 STEP Roundtable Q. 4, 2018-0743951C6 - Safe income and estate -- summary under Subsection 70(6)

CRA considers that there is no flow-through to the estate and beneficiaries of safe income attributable to shares where they were deemed to have been disposed of on death for their fair market value (thereby crystallizing that safe income in the shares’ stepped-up adjusted cost base) whereas the safe income does flow through where there was a rollover of the shares under s. 70(6).