CRA accepts that the 10-year deferral election under s. 159(6.1) is available for tax on s. 104(5.2) deemed dispositions of resource properties

S. 159(6.1) allows trusts to elect to spread a tax liability, arising as a result of a deemed disposition occurring at a time specified in s. 104(4)(a) to (c) (e.g., under the 21-year deemed disposition rule), over 10 years. CRA accepts that since s. 104(5.2) indirectly references those deemed disposition times, the election can also be used for a liability arising from a deemed disposition of resource properties under s. 104(5.2).

Neal Armstrong. Summary of 29 July 2015 T.I. 2015-0594201E5 under s. 159(6.1).