From question 7 of the 2015 APFF roundtable: if Mr X’s estate claims the capital gain exemption in his terminal return in respect of a gain realized on his deemed disposition of Opco shares, then the resulting addition to the shares’ basis will be soft basis in the hands of his son for the purposes of section 84.1 because of the application of subparagraph 84.1(2)(a.1)(ii).
