28 October 2024 Internal T.I. 2024-1029911I7 - Subparagraph 152(4)(b)(vii) and section 94 -- summary under Clause 152(4)(b)(iii)

A s. 94(3) trust reported a capital gain from the disposition of the shares of a foreign affiliate in its 2020 T3 return. After finding that s. 152(4)(b)(vii) did not authorize CRA to reassess the trust within three years of the expiry of the normal reassessment period to adjust the proceeds of disposition, the Directorate then stated:

Clause 152(4)(b)(iii)(B) may, however, have application depending on the circumstances.