The narrowing of “taxable Canadian property” also has narrowed s. 119 relief

S. 119 provides relief from double taxation where an individual paid income taxes under s. 128.1(4), on emigrating from Canada, on accrued gains on shares and subsequently received dividends on those shares that were subject to Part XIII tax. However, such relief is only available where the shares were taxable Canadian property.

Neal Armstrong. Summary of Henry Shew, "Section 119: Flawed Relief from Departure Tax," Canadian Tax Focus, Vol. 6, No. 2, May 2016, p.9 under s. 119.