In 2015-0594461E5, the CRA indicated that a taxpayer’s intention not to claim a capital gains exemption is irrelevant to the application of the ACB grind under subsection 84.1(2.1) of the Income Tax Act (Canada) which deems a taxpayer to have taken a capital gains exemption in the event the taxpayer claims a subparagraph 40(1)(a)(iii) reserve on the disposition of shares to which section 84.1 applies.