Income Tax Severed Letters - 2008-03-07

Technical Interpretation - External

25 September 2098 External T.I. 98071150 - Sale of Shares of a Non-resident Company

Unedited CRA Tags
38

Principal Issues: Tax consequence of sale of shares of a foreign country

Position: Realization of capital gain based on the fair market value of the shares over their adjusted cost base

Reasons: section 38 of the Act