CRA finds that there is implied receipt of deemed proceeds

S. 69(11) can apply to deem a taxpayer which thought it disposed of property on a rollover basis to have instead received higher proceeds of disposition (without explicitly deeming the taxpayer to have received those additional deemed proceeds) whereas the replacement property rollover in s. 44 potentially applies to "an amount that has become receivable by a taxpayer." CRA has now stated that "while subsection 69(11) does not specifically deem the taxpayer to have an amount receivable as proceeds of disposition… CRA will generally accept that this will not, in and by itself, prevent a taxpayer from making [the replacement property] election."

Essentially the same point arises elsewhere, e.g., presumably deemed proceeds of a REIT should also be considered to be "gross REIT revenue," i.e., amounts which are "received or receivable" by it.

Neal Armstrong.  Summary of 23 December 2014 T.I. 2014-0551841E5 under s. 44(1).