CRA confirms that the s. 110.6(15)(a)(i) valuation rule extends to the ss. 83.1(2.31) and (2.32), and the s. 110.63, rules

CRA confirmed that s. 110.6(15)(a)(i) (regarding the valuation of a life insurance policy at its cash surrender value) applied for purposes of the requirement in ss. 84.1(2.31) and (2.32) that the subject shares be qualified small business corporation shares (QSBC shares) and for the purposes of the draft definition in s. 110.63(1) of a “qualifying Canadian entrepreneur incentive property,” being a property that, at the time of disposition, is a share that would be a QSBC share.

However, as the definition of QSBC share and small business corporation were not relevant to the determination of whether a disposition of a share of a subject corporation was a “qualifying business transfer” under the s. 248(1) definition for purposes of the employee ownership trust rules, the deeming rule in s. 110.6(15)(a)(i) did not apply for such purposes.

Neal Armstrong. Summaries of 18 September 2025 Roundtable, 2025-1067931C6 - CLHIA 2025 - Q.2 under s. 84.1(2.31)(b)(iii), s. 110.63(1) - “qualifying canadian entrepreneur incentive property” - (a) and s. 248(1) - “qualifying business transfer”.