CRA indicates that a property transfer as collateral generally would not entail a disposition

Before concluding that “generally speaking, a disposition would not occur when publicly traded shares owned by a taxpayer are transferred to another person for the purpose only of securing a debt or loan,” CRA stated:

A key factor in determining whether property (such as shares of a publicly traded corporation) is transferred for the purposes only as security for a debt or loan includes whether the transferor intended not to give up (and the transferee not to acquire) absolute ownership (i.e., beneficial ownership) of the property.

Neal Armstrong. Summary of 26 September 2023 External T.I. 2023-0984971E5 under s. 248(1) – disposition – (j).