10 October 2014 APFF Roundtable, 2014-0538261C6 F - Disposition of capital interest/personal trust -- summary under Subsection 107(2)

Where a discretionary personal trust issues a note to a beneficiary in satisfaction of her capital interest, CRA considers that "the issuance of a note does not constitute the distribution of property of a trust to a beneficiary," so that s. 107(1) would not apply to deem her to have a high ACB for her capital interest, and s. 107(2) would not apply to the note issuance. See detailed summary under s. 108(1) – cost amount.