After the questioner referenced the previous position that, in the context of Treaty references to shares deriving in their value principally from real property, CRA would accept a valuation method that assigned the debt of a company to the assets to which the debt reasonably related, CRA stated:
In the context of tax treaties...the determination whether a share of a company derives its value principally from real or immovable property situated in Canada should be made by reference to the value of the properties of the company without taking into account its debts or other liabilities. This approach is in line with paragraph 28.4 of the [OECD] Commentary....[T]his new more restrictive position will initially be applied only with respect to dispositions of properties that are acquired after 2011.