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Time of acquisition 1.28 Generally, a taxpayer will be considered to have acquired a depreciable property at the earlier of: the date on which title to it is obtained; and the date on which the taxpayer has all the incidents of ownership such as possession, use, and risk, even if the vendor retains legal title as security for the purchase price (as is commercial practice under a conditional sale agreement). ... Cost of demolishing old building 1.55 If an old building used by a taxpayer for a long time to earn income is demolished to build a new one, the cost of demolition is not considered to be part of the capital cost of the new building (unless the taxpayer so desires), but may be deducted as an expense in the year. Determination of cost 1.57 …[T]he taxpayer is considered to have acquired a building or other structure, at any particular time, to the extent of: the construction costs incurred by the taxpayer to that time, including the cost to the taxpayer of materials that have been put in place, but not including holdbacks that constitute a conditional liability (for example, a holdback which requires that the work be approved by the taxpayer's architect or engineer before payment), or progress billings received by the taxpayer to that time, net of any holdbacks that constitute a conditional liability. ...

This anti-avoidance provision will apply where a new corporation would be considered not to deal at arm's length with a predecessor corporation as a result of a transaction or series of transactions the principal purpose of which may reasonably be considered to have been to cause subsection 1100(2.2) or 1102(14) of the Regulations to apply to a given amalgamation. ...

[A] person is beneficially interested in a trust if they have any right to receive any of the income or capital of the trust as a beneficiary of a trust either directly from the trust or indirectly through one or more trusts or partnerships. 2.14 In the context of registered plans, this means that a controlling individual who holds units of an investment trust in their registered plan would be considered to be a beneficiary of that investment trust. ... This would be the case where an individual holds a sufficient number of rights such that they would not be considered to be dealing at arm’s length with the underlying corporation, partnership or trust either as a factual matter or, in the case of a corporation, because the application of subparagraph 251(5)(b)(i) results in the individual being treated as having control of the corporation and thus related to the corporation. ...