CRA treats the granting of an emphyteusis as a part disposition of property rather than as a lease

CRA now considers that the entering into of an emphyteutic lease represents a part disposition of property rather than something analogous to the entering into of a common law lease.  Therefore, any "rents" receivable must be recognized as proceeds of disposition at the time of grant rather than as amounts which can be recognized over time as they become receivable (although a s. 40(1) reserve may be available).  This represents a reversal of a 2012 technical interpretation.

Neal Armstrong. Summary of 23 December 2014 T.I. 2013-0487791E5 F under s. 248(1) – disposition.