22 December 2021 External T.I. 2021-0914081E5 - RPP in-kind distribution -- summary under Paragraph 149(1)(o)

After indicating that where a registered pension plan trust made a distribution-in-kind to a member, the resulting inclusion of the distributed property’s FMV in the member’s income pursuant to s. 56(1)(a)(i) meant that such amount was deemed to be the cost of the property to the individual pursuant to s. 52(1), CRA went on to indicate that pursuant to the exemption in s. 149(1)(o), “any taxable capital gain arising from the disposition of the property distributed from the RPP to the member will not give rise to any Part I tax to the RPP trust.”