CRA considers the assignment of a right to purchase Canadian real estate to be a disposition of taxable Canadian property

CRA considers that a right to acquire a Canadian real estate property (presumably under an agreement of purchase and sale) is an “option” in respect of the property under para. (f) of the taxable Canadian property definition, so that an assignment of such right by a non-resident constitutes a disposition of taxable Canadian property.

It is unclear why CRA considers such a right to be an option in respect of the property rather than (in a common law province) an equitable interest in the property. It would be news to an options trader that a binding obligation to acquire a property was an option.

Neal Armstrong. Summary of 2015-0608211E5 under s. 248(1) - taxable Canadian property - (f).