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s. 80.6

PART I — Income Tax · DIVISION B — Computation of Income · SUBDIVISION F — Rules Relating to Computation of Income

Synthetic disposition

Not yet annotated · Text current to 2026-06-21 · section last amended 2013-12-12

Current text

(1)

If a synthetic disposition arrangement is entered into in respect of a property owned by a taxpayer and the synthetic disposition period of the arrangement is one year or more, the taxpayer is deemed

(a)

to have disposed of the property immediately before the beginning of the synthetic disposition period for proceeds equal to its fair market value at the beginning of the synthetic disposition period; and

(b)

to have reacquired the property at the beginning of the synthetic disposition period at a cost equal to that fair market value.

Exception

(2)

Subsection (1) does not apply in respect of a property owned by a taxpayer if

(a)

the disposition referred to in subsection (1) would not result in the realization of a capital gain or income;

(b)

the property is a mark-to-market property (as defined in subsection 142.2(1)) of the taxpayer;

(c)

the synthetic disposition arrangement referred to in subsection (1) is a lease of tangible property or, for civil law, corporeal property;

(d)

the arrangement is an exchange of property to which subsection 51(1) applies; or

(e)

the property is disposed of as part of the arrangement, within one year after the day on which the synthetic disposition period of the arrangement begins.

Source: Justice Laws Website. Not an official version.

Historic text

This section has not been amended since it was enacted (2013, c. 40, s. 38), so there is no earlier version.

Earlier versions: Justice Laws point-in-time versions of the Act (from 31 August 2004), and CanLII (under “Versions”). On Justice Laws, each version of section 80.6 links to the one before it.

Enacting and amending legislation

  • 2013, c. 40, s. 38

Text before 2004 is found in the annual Statutes of Canada cited above. Application and coming-into-force provisions are not part of the consolidation; see the amending Acts.

Cross-references

This section refers to

s. 51s. 142.2

References are generated from the statutory text and list other sections of the Act only.

Citation

Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.), s. 80.6.