CRA indicates that “consideration … received” in s. 118.1(13)(c) includes a s. 84(3) deemed dividend

Under s. 118.1(13)(c), where a qualified donee that disposes of non-qualifying securities (“NQS”) that were gifted to it, the amount of the original gift will be deemed in some circumstances to equal the fair market value of the “consideration” received by the donee for that subsequent disposition.

CRA indicated that, unless the context indicates otherwise, “the notion of ‘consideration’ is broad enough to encompass any amount, good or service received upon the disposition of property,” so that the “consideration” received by the donee would not be limited to s. 54 proceeds of disposition, and would include a deemed dividend received by the qualified donee under s. 84(3) on a redemption of shares.

Neal Armstrong. Summary of 8 October 2021 APFF Roundtable, Q.14 under s. 118.1(13)(c).