Where surplus from an individual pension plan trust (IPP) is distributed as an in-kind distribution to the sole member, what is the cost to the member of property thereby received from the IPP?
After noting that the questions were relevant to any registered pension plan (RPP), not just an IPP, and that the in-kind distribution would constitute the disposition and acquisition of the distributed property occurring at its fair market value (FMV) at the time of the distribution, and that such amount would be included in the member’s income under s. 56(1)(a)(i), CRA then indicated that, pursuant to s. 52(1), the FMV of the property that was included in computing the member’s income would be deemed to be the cost to the member of such property.