In 2013-0506561I7 (recently released), the CRA said the cost of property received by a Canadian corporate shareholder (Canco) from its foreign affiliate, on a return of capital in 2008, was the fair market value (FMV) of the property at that time.  In addition, the same reasoning applied as to whether Canco had "made or incurred an outlay or expense" for purposes of the eligible capital expense (ECE) rules in s. 14 (see page 5).  Accordingly, Canco could amortize the FMV cost of such property under s. 20(1)(b) provided the property qualified as an eligible capital property of Canco.