3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 6, 2023-0994241C6 F - Consequences of Transfer of DSUs to a corporation -- summary under Subsection 85(1.1)

In finding that the rights of an employee under a deferred share unit plan described in Reg. 6801(d) (a "DSU Plan") were not eligible property that could be transferred to the employee’s personal holding company under s. 85(1), CRA stated that an “employee's rights under a DSU Plan generate income from an office or employment” rather than being capital property.