Spin-off tax and cost base allocation

When a company spins off a division, you end up holding two stocks where you had one — and your original cost base has to be split between them.

Updated July 2026 · 6 min read

What a spin-off does to your holdings

In a spin-off, a company distributes shares of a subsidiary to its shareholders, so you now own both the parent and the spun-off entity. Your total economic position hasn’t changed at the moment of the spin-off, but your single cost base now has to be allocated across two securities.

Splitting the ACB

You divide your original ACB between the parent and the new shares, typically in proportion to their relative fair market values just after the spin-off. The company or your broker usually publishes the recommended allocation percentages.

Worked example. Original ACB $10,000. Post-spin-off values suggest 80% parent / 20% spin-off. Your parent ACB becomes $8,000 and the new shares’ ACB $2,000. The total is still $10,000.

Foreign spin-offs can be taxable

Spin-offs from US and other foreign corporations are often treated as a taxable foreign dividend by default — potentially a nasty surprise. Canada offers section 86.1, which lets eligible foreign spin-offs be received on a tax-deferred basis if you elect on your return for the year. The election is not automatic; miss it and the distribution can be fully taxable.

Getting it right later

The allocation you set at the spin-off drives the capital gain on both stocks whenever you eventually sell either one — sometimes years later. A misallocation quietly distorts two future gains, which is why recording it correctly at the time matters.

Split an original cost base across the parent and spun-off shares using the published allocation percentages.

The corporate action
What happened?
e.g. Brookfield's 2022 manager spin-off gave 0.25 BAM per BN share
From the issuer's tax letter (usually on their investor-relations page)
Currency of the amounts above
What this means for your ACB
ACB moved to the new shares
$600.00
ACB left on the parent
$4,400.00
You receive 25 new-company shares. Their combined cost base is $600.00 (12% of your old ACB), which is $24.00 per share. The parent keeps the rest. On a qualifying Canadian spin-off (or a foreign one with a section 86.1 election) there is no disposition.
Why this matters: brokers routinely show the post-action book value wrong — especially the ACB split between parent and spin-off, and rolled-over ACB after a takeover. When you eventually sell, the T5008 cost box will not know about any of this. You are responsible for the correct ACB on Schedule 3.

Frequently asked

How do I handle a spin-off on my Canadian taxes?

Allocate your original adjusted cost base between the parent and the spun-off shares, usually in proportion to their fair market values just after the spin-off. Your total ACB is unchanged; it is simply split across two securities.

Are foreign spin-offs taxable in Canada?

Often yes — a foreign spin-off can be treated as a taxable foreign dividend by default. Section 86.1 allows eligible foreign spin-offs to be received tax-deferred, but only if you make the election on your return for that year.

What is a section 86.1 election?

It is an election that lets you receive an eligible foreign spin-off on a tax-deferred basis instead of as a taxable dividend, splitting your cost base across the shares. It must be claimed on your return; it is not applied automatically.

Keep reading
Stock splits and your cost baseWhat is adjusted cost base?US stocks and Canadian tax

Educational information, not tax advice. Rules summarized here can change and may not fit your situation — always confirm your capital gains reporting with a qualified Canadian accountant.

Not tax or legal advice. Always confirm capital gains reporting with a qualified accountant. · Made with love in Canada 🇨🇦
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