The s. 220(4.51) exemption from providing departure-tax security on up to $100,000 of capital gains is available for larger gains

The Rulings Directorate confirmed that, for purposes of calculating the s. 220(4.5) security for departure tax that an emigrating individual has elected to defer, the individual qualifies for the exemption under s. 220(4.51) from providing security on the first $100,000 of capital gains even if such gains exceed $100,000.

Neal Armstrong. Summary of 5 June 2017 Internal T.I. 2014-0561391I7 F under s. 220(4.51).