CRA confirms that the departure tax deferral under s. 220(4.5)(a)(i) is available for AMT payable because of s. 128.1(4)(b)

CRA confirmed that, where an individual was deemed by s. 128.1(4)(b) to dispose of property on exiting Canada, it was possible that the amount of minimum tax calculated pursuant to s. 127.5(a) would exceed the (regular) tax otherwise payable by the individual under Division E, exclusive of s. 120. CRA went on to find that the election under s. 220(4.5) would allow the individual to defer the payment of an amount equal to the excess of such AMT over the tax that would otherwise have been payable by the individual for the year of emigration but for the application of s. 128.1(4)(b).

Neal Armstrong. Summary of 9 October 2025 APFF Roundtable, Q.10 under s. 220(4.5)(a)(i).