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Abstract
Recently, the Canada Revenue Agency (CRA) announced it was changing its policy for determining whether shares of a corporation will be considered TCP. the CRA said the determination of "whether a share derives its value principally from real or immovable property situated in Canada should be made by reference to the value of the properties of the company without taking into account its debts or other liabilities". The CRA acknowledged this gross asset value test is different from its past position, but noted that it is consistent with the real property test in Canada's tax treaties. This new position will initially apply to dispositions of properties acquired after 2011. As of January 1 2013, the determination of TCP for all dispositions will be subject to the gross asset value test.