Inheriting a $500,000 Non-Registered Stock Portfolio in Canada 2026: Deemed Disposition, Capital Gains and What the Estate Owes

Michael Chen, CFP
15 min read

Key Takeaways

  • 1Understanding inheriting a $500,000 non-registered stock portfolio in canada 2026: deemed disposition, capital gains and what the estate owes is crucial for financial success
  • 2Professional guidance can save thousands in taxes and fees
  • 3Early planning leads to better outcomes
  • 4GTA residents have unique considerations for inheritance planning
  • 5Taking action now prevents costly mistakes later

Quick Summary

This article covers 5 key points about key takeaways, providing essential insights for informed decision-making.

Quick Answer

When a Canadian investor dies holding a $500,000 non-registered stock portfolio with an adjusted cost base (ACB) of $175,000, the CRA treats those shares as sold at fair market value on the date of death — a deemed disposition. The capital gain is $325,000. Under the 2026 inclusion rate, the first $250,000 of gains is included at 50% ($125,000 taxable), and the remaining $75,000 is included at 66.67% ($50,003 taxable). Total taxable capital gain: $175,003. On the terminal T1 return, assuming $60,000 of other income, the combined federal and Ontario tax on the capital gains portion is approximately $62,000–$68,000. The beneficiaries inherit the portfolio at a stepped-up ACB equal to the fair market value at death ($500,000), meaning they owe zero capital gains on the amount already taxed. On a two-beneficiary estate, each receives approximately $216,000–$219,000 after all estate taxes, probate fees, and administration costs are paid.

Key Takeaways

  • 1A $500,000 non-registered stock portfolio with a $175,000 ACB triggers a $325,000 deemed capital gain on the terminal T1 return — the CRA treats death as a sale at fair market value.
  • 2Under 2026 rules, the first $250,000 of capital gains is included at 50% and the excess at 66.67%, producing approximately $175,003 in taxable income from the portfolio alone.
  • 3The estate owes approximately $62,000–$68,000 in combined federal and Ontario tax on the capital gains, depending on the deceased's other income in the year of death.
  • 4Canadian-listed equities are straightforward — the ACB and FMV are both in Canadian dollars. Foreign-listed stocks (e.g., U.S. equities held in a non-registered account) require a separate currency gain calculation that can increase the taxable amount.
  • 5The executor can carry back capital losses from the first tax year of the estate to offset capital gains on the terminal T1 — a powerful tool if markets drop after the date of death.
  • 6Beneficiaries inherit each position at a stepped-up ACB equal to the date-of-death fair market value, meaning they owe no tax on the gains already taxed on the terminal T1.
  • 7The executor controls when to liquidate positions after death — selling in the same calendar year vs. the next can shift income between the terminal T1 and the estate's T3 return, managing the marginal tax rate.
  • 8In a two-beneficiary estate, each person receives approximately $216,000–$219,000 after estate taxes, probate, legal, and accounting fees are deducted from the $500,000 portfolio.

Quick Summary

This article covers 8 key points about key takeaways, providing essential insights for informed decision-making.

How the Deemed Disposition Works on Non-Registered Stocks at Death

Canada does not have an inheritance tax. Instead, the Income Tax Act (subsection 70(5)) treats the deceased as having sold all non-registered capital property at fair market value (FMV) immediately before death. This is the deemed disposition — a legal fiction that triggers capital gains tax on the deceased's terminal T1 return, even though no shares were actually sold.

For a non-registered stock portfolio, this means every position is treated as sold at the closing price on the date of death. The difference between the original adjusted cost base (ACB) and the date-of-death FMV is the capital gain (or loss) reported on the terminal T1. The estate — not the beneficiaries — is responsible for paying the resulting tax.

Critical Distinction: Non-Registered vs. Registered Accounts

This article covers non-registered (taxable) brokerage accounts only. Registered accounts (RRSP, RRIF, TFSA) follow different rules at death. RRSPs inherited by adult children are included as ordinary income (not capital gains) on the terminal T1 — a much higher tax rate. TFSAs can transfer tax-free to a successor holder. Non-registered stocks fall in between: taxed as capital gains with partial inclusion, making them more tax-efficient than RRSPs but not tax-free like TFSAs.

The Portfolio: $500,000 FMV, $175,000 ACB — Position by Position

To model the deemed disposition concretely, we use a realistic five-position portfolio held by an Ontario resident who dies in 2026. The portfolio includes both Canadian and U.S.-listed equities.

PositionSharesACB (Total)FMV at DeathCapital Gain
Royal Bank (RY.TO)800$52,000$116,000$64,000
Enbridge (ENB.TO)1,500$42,000$87,000$45,000
CN Railway (CNR.TO)400$28,000$70,000$42,000
Apple Inc. (AAPL)*300$27,000$93,000$66,000
Microsoft (MSFT)*250$26,000$134,000$108,000
Total$175,000$500,000$325,000

*U.S.-listed equities — ACB and FMV converted to Canadian dollars using the Bank of Canada exchange rate on the respective transaction dates.

Capital Gains Inclusion: The 2026 Two-Tier Rate

Under the 2026 capital gains rules, the inclusion rate depends on the amount of gains realized:

  • First $250,000 of capital gains: Included at 50% — meaning $125,000 is added to taxable income
  • Capital gains above $250,000: Included at 66.67% — the remaining $75,000 of gains produces $50,003 of taxable income

Inclusion Calculation

Gain TierCapital GainInclusion RateTaxable Amount
First $250,000$250,00050%$125,000
Above $250,000$75,00066.67%$50,003
Total$325,000$175,003

Terminal T1 Tax Calculation: What the Estate Actually Owes

The deemed disposition gain is added to the deceased's other income for the year of death. For this model, we assume the deceased had $60,000 of employment/pension income before death, bringing total taxable income to $235,003.

Terminal T1 — Combined Federal + Ontario Tax

Income ComponentAmount
Employment/pension income$60,000
Taxable capital gain (deemed disposition)$175,003
Total taxable income$235,003
Federal tax on $235,003~$42,400
Ontario tax on $235,003~$17,600
Less: tax already paid on $60,000 (withholding)−$11,700
Additional tax owing on terminal T1~$48,300

The total combined tax on the capital gains component alone is approximately $62,000–$68,000. The deceased's other credits (basic personal amount, age amount, pension income amount, medical expenses) will reduce the final balance owing.

Why the Range? $62,000–$68,000

The exact tax depends on credits available on the terminal T1 — the basic personal amount ($17,129 federal credit in 2026), any medical expenses in the final year, charitable donations (which receive enhanced credit on the terminal return), and whether the deceased had eligible pension income for the pension income amount credit. A deceased person with significant medical expenses or charitable bequests in the will could reduce the tax by $5,000–$10,000 or more.

Canadian Equities vs. Foreign-Listed Stocks: The Currency Gain Component

The three Canadian-listed positions (Royal Bank, Enbridge, CN Railway) are straightforward — the ACB and FMV are both in Canadian dollars, and the capital gain is simply the difference between them.

The two U.S.-listed positions (Apple, Microsoft) require an additional step. The CRA requires that both the ACB and the proceeds of deemed disposition be reported in Canadian dollars, using the Bank of Canada exchange rate on the respective dates. This means the total capital gain includes both the stock price appreciation in USD and any currency gain from changes in the CAD/USD exchange rate.

Currency Impact Example — Apple Inc.

ComponentPurchase DateDate of Death
Share price (USD)US$65.00US$225.00
CAD/USD exchange rate1.3851.378
Value in CAD (300 shares)C$27,008C$93,015
Capital gain in CADC$66,007

In this example, the Canadian dollar slightly strengthened (1.385 → 1.378), marginally reducing the Canadian-dollar gain. If the loonie had weakened to 1.45, the same U.S. stock appreciation would produce a significantly larger Canadian-dollar gain.

For estates with large U.S. equity holdings accumulated during a period of Canadian dollar weakness, the currency gain can represent 20%–40% of the total capital gain — a factor that surprises many beneficiaries. The executor must obtain the Bank of Canada daily exchange rate for each original purchase date and for the date of death to calculate the correct Canadian-dollar ACB and FMV.

Capital Loss Carryback: Subsection 164(6) Election

One of the most powerful — and underused — estate tax planning tools is the ability to carry back capital losses from the estate's first tax year to the deceased's terminal T1 return under subsection 164(6) of the Income Tax Act.

Here is how it works: if the stock portfolio declines in value after the date of death and the executor sells positions at a loss, those losses can be applied retroactively against the deemed disposition gains on the terminal T1. This reduces the terminal T1 tax bill and generates a refund.

Example: Market Drops 10% After Death

The portfolio was worth $500,000 at death (triggering a $325,000 deemed gain). Three months later, the executor sells all positions for $450,000. The estate realizes a $50,000 capital loss ($500,000 stepped-up ACB minus $450,000 sale proceeds). Using the 164(6) election, the executor carries this $50,000 loss back to the terminal T1, reducing the net capital gain from $325,000 to $275,000. The tax savings: approximately $8,000–$12,000 depending on the marginal rate.

Requirements for the 164(6) Election

The loss must be realized in the estate's first taxation year. The executor can choose a non-calendar fiscal year-end for the estate (e.g., if death occurs on March 15, the first fiscal year could end on February 28 of the following year — giving 11.5 months to monitor markets and decide whether to sell). The election is made by letter attached to the terminal T1 or by amending the terminal T1 after the estate's first year ends.

Executor Strategy: Don't Rush to Sell

Many executors immediately liquidate the entire portfolio to "simplify" the estate. This forfeits the option value of the 164(6) election. If markets decline after death, waiting to sell allows the executor to harvest capital losses that directly reduce the terminal T1 tax bill. If markets rise, the executor can still sell — the post-death gain is taxed on the estate's T3 return at graduated rates (if the estate qualifies as a Graduated Rate Estate). The executor should consult with the estate accountant before making large-scale liquidation decisions.

Executor Timing: Managing the Tax Bracket Through Strategic Liquidation

The executor has discretion over when to sell estate assets, and this timing directly affects which tax return bears the income and at what marginal rate. The key principle: income earned before death goes on the terminal T1, while income earned after death goes on the estate's T3 return.

Timing Strategies

StrategyWhen It WorksTax Benefit
Hold and distribute in-kindBeneficiaries want the positions; no immediate cash neededNo post-death capital gains; beneficiaries control their own timing
Sell in estate's first fiscal yearCash needed for taxes/debts; market has declined (164(6) loss)Capital losses carry back to terminal T1; potential $8K–$12K savings
Stagger sales across fiscal yearsEstate has GRE status; positions have appreciated since deathSpreads post-death gains across T3 years; keeps each year in lower brackets
Sell immediatelyVolatile positions; beneficiaries want cash; market at highsLocks in value; minimal post-death gain/loss

If the estate qualifies as a Graduated Rate Estate (GRE) — meaning it is within 36 months of death and is designated as the GRE on the T3 return — post-death income is taxed at graduated rates just like an individual, rather than at the flat top rate. This makes bracket management meaningful: a $30,000 capital gain in one T3 year is taxed at a much lower effective rate than a $90,000 gain compressed into a single year.

Before and After: What Each Beneficiary Actually Receives

Here is the complete before/after table showing how the $500,000 portfolio is reduced by estate costs and what two equal beneficiaries ultimately receive.

ItemAmount
Gross portfolio value at death$500,000
Capital gains tax (terminal T1)−$65,000
Ontario probate fees (Estate Administration Tax)−$7,250
Legal fees (estate administration + probate)−$8,000
Accounting fees (terminal T1 + T3)−$4,000
Executor compensation (2.5% if claimed)−$12,500
Miscellaneous (certificates, courier, fees)−$500
Net estate available for distribution$402,750
Beneficiary A (50%)$201,375
Beneficiary B (50%)$201,375

If the executor waives compensation: net estate = $415,250 ($207,625 per beneficiary). If the executor successfully carries back $50,000 in capital losses via s.164(6): net estate increases by ~$10,000, bringing each beneficiary's share to ~$206,000–$212,000.

The 17%–19% Shrinkage Factor

Of the original $500,000 portfolio, approximately $85,000–$97,000 (17%–19%) goes to taxes, fees, and administration costs. The single largest cost is the capital gains tax on the deemed disposition — which is why strategies like spousal rollovers, charitable donations in the will, and loss carrybacks are critical estate planning tools. For a portfolio with a lower ACB (higher embedded gains), the shrinkage can exceed 25%.

Strategies to Reduce the Deemed Disposition Tax Bill

While the deemed disposition is unavoidable on non-registered assets (unless transferring to a surviving spouse), several strategies can reduce the tax impact:

1. Spousal Rollover (Subsection 70(6))

If the portfolio is left to a surviving spouse (or a qualifying spousal trust), the deemed disposition is deferred. The surviving spouse inherits the shares at the original ACB, and capital gains are not triggered until the surviving spouse dies or sells. This completely eliminates the $65,000 tax bill at first death — but shifts it to the second death.

2. Charitable Donations in the Will

Charitable donations made through the will (or within 60 months of death) generate a donation tax credit on the terminal T1 with no cap — unlike the 75% net income limit for living donations. A $50,000 charitable bequest generates approximately $22,000–$25,000 in tax credits, partially offsetting the capital gains tax. Donating appreciated securities directly to a registered charity eliminates the capital gains tax on those specific shares entirely.

3. Capital Loss Carryback (s.164(6))

As discussed above, if markets decline after death, the executor can sell positions at a loss in the estate's first tax year and carry those losses back to offset the terminal T1 deemed disposition gains.

4. Lifetime ACB Management

The best time to reduce the deemed disposition tax bill is before death. By periodically realizing capital gains during lifetime — selling and immediately rebuying positions to reset the ACB higher — the investor pays capital gains tax at potentially lower rates (when income is lower) and reduces the deemed disposition gain at death. This "ACB reset" strategy is especially valuable for retirees in low-income years between retirement and age 72 (when RRIF minimums begin).

The Stepped-Up ACB: What Beneficiaries Inherit

After the deemed disposition taxes are paid, the beneficiaries inherit each position at a stepped-up adjusted cost base equal to the fair market value on the date of death. This is the critical benefit of the deemed disposition system — the gains that were taxed on the terminal T1 are never taxed again.

Beneficiary ACB After Inheritance

PositionDeceased's ACBBeneficiary's New ACBACB Reset
Royal Bank (RY.TO)$65.00/share$145.00/share+$80.00
Enbridge (ENB.TO)$28.00/share$58.00/share+$30.00
CN Railway (CNR.TO)$70.00/share$175.00/share+$105.00
Apple Inc. (AAPL)C$90.00/shareC$310.00/share+C$220.00
Microsoft (MSFT)C$104.00/shareC$536.00/share+C$432.00

If Beneficiary A sells their inherited Royal Bank shares at $150.00, they only pay capital gains tax on the $5.00 per share increase above the $145.00 stepped-up ACB — not the full $85.00 gain from the original $65.00 purchase price.

The Bottom Line

A $500,000 non-registered stock portfolio with a $175,000 ACB triggers a $325,000 deemed capital gain at death — producing approximately $175,003 in taxable income and $62,000–$68,000 in combined federal and Ontario tax. After probate fees, legal costs, accounting fees, and executor compensation, the two beneficiaries each receive approximately $201,000–$212,000 of the original $500,000.

The executor's most impactful decisions are: (1) whether to use the subsection 164(6) loss carryback if markets decline after death, (2) whether to distribute shares in-kind or liquidate, (3) how to time any sales across the estate's fiscal years to manage the marginal tax bracket, and (4) whether a spousal rollover could have deferred the entire bill. These are not decisions to make without professional guidance — the difference between good and poor execution on a $500,000 portfolio can easily be $10,000–$20,000.

Frequently Asked Questions

Q:How is the adjusted cost base (ACB) established for inherited stocks in Canada?

A:When shares are transferred to beneficiaries through an estate, the beneficiaries receive the shares at a stepped-up adjusted cost base equal to the fair market value on the date of the deceased's death. This is because the deemed disposition on the terminal T1 already taxed the gain from the original ACB to the date-of-death FMV. For example, if the deceased purchased 1,000 shares of Royal Bank at $45 per share (ACB = $45,000) and the shares were worth $140 per share at death (FMV = $140,000), the estate pays capital gains tax on the $95,000 gain. The beneficiary inherits the shares with an ACB of $140 per share. If the beneficiary later sells at $160 per share, they only owe capital gains tax on the $20 per share increase — not the full $115 per share gain from the original purchase price. This stepped-up ACB prevents double taxation of the same gain.

Q:What happens to foreign-listed stocks (U.S. equities) in a non-registered account at death?

A:Foreign-listed stocks held in a non-registered Canadian brokerage account are subject to two layers of gain calculation at death. First, there is the capital gain in the foreign currency — the difference between the U.S. dollar purchase price and the U.S. dollar fair market value at death. Second, there is the currency gain or loss — the difference in the CAD/USD exchange rate between the purchase date and the date of death. Both components are combined into the total Canadian-dollar capital gain reported on the terminal T1. For example, if the deceased bought 500 shares of Apple at US$120 when the exchange rate was 1.25 (ACB = C$75,000), and at death the shares are worth US$200 with an exchange rate of 1.38 (FMV = C$138,000), the total capital gain is C$63,000 — which includes both the stock price appreciation and the currency gain. The CRA requires the ACB and proceeds to both be reported in Canadian dollars using the exchange rate on the respective transaction dates.

Q:Can the executor carry back capital losses to reduce the terminal T1 tax bill?

A:Yes. Under subsection 164(6) of the Income Tax Act, the executor (legal representative) can elect to carry back capital losses realized in the first tax year of the estate to the deceased's terminal T1 return. This is one of the most powerful tax planning tools available to executors. If the stock portfolio declines in value after the date of death and the executor sells positions at a loss, those losses can be applied against the deemed disposition gains on the terminal T1. For example, if the terminal T1 reports a $325,000 deemed capital gain, but the executor sells positions in the estate's first tax year at a $50,000 loss, the executor can elect to treat that $50,000 loss as if it occurred on the terminal T1 — reducing the net capital gain to $275,000 and saving approximately $8,000–$12,000 in tax. The election must be filed with the terminal T1 or by amending it, and the loss must arise in the estate's first taxation year (which can be up to 12 months after death if the executor chooses a non-calendar fiscal year for the estate).

Q:How does the executor time asset liquidation to manage the tax bracket?

A:The executor has discretion over when to sell estate assets, and this timing directly affects which tax return bears the income. Income earned on assets before the date of death is reported on the terminal T1. Income earned after death — including capital gains from selling positions post-death — is reported on the estate's T3 return. If the estate qualifies as a Graduated Rate Estate (GRE), the T3 return uses the same graduated tax brackets as an individual. The executor can strategically time sales: selling positions that have appreciated since death in a year when the estate has little other income keeps the gains in lower brackets. Conversely, if the estate has significant income in its first year, the executor might delay sales to the second year. The executor can also choose the estate's fiscal year-end (it does not have to be December 31 for the first 36 months), giving additional flexibility to split income across tax years. This bracket management can save $5,000–$15,000 on a $500,000 portfolio depending on the estate's total income profile.

Q:Do beneficiaries pay tax when they receive inherited stocks from an estate?

A:No. Beneficiaries do not pay income tax when they receive stocks distributed from a Canadian estate. The capital gains tax was already paid by the estate on the terminal T1 return through the deemed disposition. The beneficiaries receive the shares at the stepped-up ACB (fair market value at date of death), and they only owe capital gains tax on any future appreciation above that stepped-up cost. However, beneficiaries should be aware of two things: (1) any dividends or interest earned on the shares while held by the estate may be allocated to beneficiaries on the estate's T3 return and included on the beneficiary's T3 slip, and (2) if the executor distributes cash instead of shares (by liquidating the portfolio), the beneficiary receives the cash tax-free — the estate already paid the tax on the deemed disposition and any post-death gains from the sale.

Q:What is the difference between deemed disposition and actual sale of inherited stocks?

A:A deemed disposition is a legal fiction created by the Income Tax Act — the CRA treats the deceased as having sold all non-registered assets at fair market value immediately before death, even though no actual sale occurred. The capital gain from this deemed sale is reported on the deceased's terminal T1 return, and the estate must pay the resulting tax. An actual sale occurs when the executor later sells the shares on the open market to raise cash for tax payments, debts, or distributions to beneficiaries. The actual sale may trigger a second capital gain or loss if the share prices have changed between the date of death (when the deemed disposition set the new ACB) and the date of the actual sale. For example, if a stock was worth $50 at death (deemed disposition price) and the executor sells it three months later for $55, the estate reports a $5 per share capital gain on its T3 return — separate from the gain already taxed on the terminal T1.

Question: How is the adjusted cost base (ACB) established for inherited stocks in Canada?

Answer: When shares are transferred to beneficiaries through an estate, the beneficiaries receive the shares at a stepped-up adjusted cost base equal to the fair market value on the date of the deceased's death. This is because the deemed disposition on the terminal T1 already taxed the gain from the original ACB to the date-of-death FMV. For example, if the deceased purchased 1,000 shares of Royal Bank at $45 per share (ACB = $45,000) and the shares were worth $140 per share at death (FMV = $140,000), the estate pays capital gains tax on the $95,000 gain. The beneficiary inherits the shares with an ACB of $140 per share. If the beneficiary later sells at $160 per share, they only owe capital gains tax on the $20 per share increase — not the full $115 per share gain from the original purchase price. This stepped-up ACB prevents double taxation of the same gain.

Question: What happens to foreign-listed stocks (U.S. equities) in a non-registered account at death?

Answer: Foreign-listed stocks held in a non-registered Canadian brokerage account are subject to two layers of gain calculation at death. First, there is the capital gain in the foreign currency — the difference between the U.S. dollar purchase price and the U.S. dollar fair market value at death. Second, there is the currency gain or loss — the difference in the CAD/USD exchange rate between the purchase date and the date of death. Both components are combined into the total Canadian-dollar capital gain reported on the terminal T1. For example, if the deceased bought 500 shares of Apple at US$120 when the exchange rate was 1.25 (ACB = C$75,000), and at death the shares are worth US$200 with an exchange rate of 1.38 (FMV = C$138,000), the total capital gain is C$63,000 — which includes both the stock price appreciation and the currency gain. The CRA requires the ACB and proceeds to both be reported in Canadian dollars using the exchange rate on the respective transaction dates.

Question: Can the executor carry back capital losses to reduce the terminal T1 tax bill?

Answer: Yes. Under subsection 164(6) of the Income Tax Act, the executor (legal representative) can elect to carry back capital losses realized in the first tax year of the estate to the deceased's terminal T1 return. This is one of the most powerful tax planning tools available to executors. If the stock portfolio declines in value after the date of death and the executor sells positions at a loss, those losses can be applied against the deemed disposition gains on the terminal T1. For example, if the terminal T1 reports a $325,000 deemed capital gain, but the executor sells positions in the estate's first tax year at a $50,000 loss, the executor can elect to treat that $50,000 loss as if it occurred on the terminal T1 — reducing the net capital gain to $275,000 and saving approximately $8,000–$12,000 in tax. The election must be filed with the terminal T1 or by amending it, and the loss must arise in the estate's first taxation year (which can be up to 12 months after death if the executor chooses a non-calendar fiscal year for the estate).

Question: How does the executor time asset liquidation to manage the tax bracket?

Answer: The executor has discretion over when to sell estate assets, and this timing directly affects which tax return bears the income. Income earned on assets before the date of death is reported on the terminal T1. Income earned after death — including capital gains from selling positions post-death — is reported on the estate's T3 return. If the estate qualifies as a Graduated Rate Estate (GRE), the T3 return uses the same graduated tax brackets as an individual. The executor can strategically time sales: selling positions that have appreciated since death in a year when the estate has little other income keeps the gains in lower brackets. Conversely, if the estate has significant income in its first year, the executor might delay sales to the second year. The executor can also choose the estate's fiscal year-end (it does not have to be December 31 for the first 36 months), giving additional flexibility to split income across tax years. This bracket management can save $5,000–$15,000 on a $500,000 portfolio depending on the estate's total income profile.

Question: Do beneficiaries pay tax when they receive inherited stocks from an estate?

Answer: No. Beneficiaries do not pay income tax when they receive stocks distributed from a Canadian estate. The capital gains tax was already paid by the estate on the terminal T1 return through the deemed disposition. The beneficiaries receive the shares at the stepped-up ACB (fair market value at date of death), and they only owe capital gains tax on any future appreciation above that stepped-up cost. However, beneficiaries should be aware of two things: (1) any dividends or interest earned on the shares while held by the estate may be allocated to beneficiaries on the estate's T3 return and included on the beneficiary's T3 slip, and (2) if the executor distributes cash instead of shares (by liquidating the portfolio), the beneficiary receives the cash tax-free — the estate already paid the tax on the deemed disposition and any post-death gains from the sale.

Question: What is the difference between deemed disposition and actual sale of inherited stocks?

Answer: A deemed disposition is a legal fiction created by the Income Tax Act — the CRA treats the deceased as having sold all non-registered assets at fair market value immediately before death, even though no actual sale occurred. The capital gain from this deemed sale is reported on the deceased's terminal T1 return, and the estate must pay the resulting tax. An actual sale occurs when the executor later sells the shares on the open market to raise cash for tax payments, debts, or distributions to beneficiaries. The actual sale may trigger a second capital gain or loss if the share prices have changed between the date of death (when the deemed disposition set the new ACB) and the date of the actual sale. For example, if a stock was worth $50 at death (deemed disposition price) and the executor sells it three months later for $55, the estate reports a $5 per share capital gain on its T3 return — separate from the gain already taxed on the terminal T1.

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