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Netfile/capital gains problem??
May 4, 2025
7:59 pm
AltaRed
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Chances are the brokerage Cost Basis is correct for most types of transactions but they will definitely be wrong in some other cases. Cost Basis is your personal responsibility, not that of the brokerage. If CRA decides to query Cost Basis, it is up to you to present the documentation on how you calculated it, including that trade confirmation slip, or account statement, or some other reference point from Investor Relations of the company issuing that security.

IOW, you must present the evidence, from 2006 if necessary if that is when you bought the security. CRA expects you to use the correct Cost Basis as Cost Basis is your own personal responsibility, not that of any other agent/brokerage, etc. I wish brokerages would have never started putting Cost Basis in the T5008. They really have no business doing so but I suspect there was pressure from somewhere, maybe CRA itself, to start reporting what 'they' carried on the form without realizing the brokerages weren't doing everything right to begin with.

Having said all that, if you use the Brokerage Cost Basis in your tax submission, there is a 99.9% chance CRA will just accept it. After all, if you present the same data as the T5008, there is not much reason for CRA to flag it for follow up. Which goes to say, whatever you have done in the past is almost 100% 'water under the bridge' and probably best left alone. You certainly would not be the first to have been doing it your way.

There are many guides on how one should record and manage Cost Basis and you are supposed to educate yourself on how to do it and to record it each and every year for each transaction and save the documentation. The two best sources to learn is from TaxTips https://www.taxtips.ca/filing/capital-gains-and-losses.htm and AdjustedCostBase.CA https://www.adjustedcostbase.ca/ which has a spreadsheet tool for you to use to track Cost Basis, and in the bottom right corner Blog, a series of articles on how to calculate cost basis. There is no "first in, first out" in Canada. It is a weighted average aggregate of all purchases.

I cannot advise you what to do with 2024 because I have no idea of the extent of your transactions or how much they may not be correct. If you say all of your transactions (purchases and sales) are in USD, I am missing how you translated USD to CAD equivalent for acquisition Cost Basis, where and how you recorded it whether that was in 2006 or 2021, and disposition CAD equivalent. To my knowledge, no brokerage does that CAD equivalent conversion for you, i.e. their T5008 will show USD transactions in USD, not CAD equivalent. And if that brokerage did so, I strongly suspect they did it wrong.

A ficticious example of a USD purchase(s) and a USD disposition follows:
- Bought 100 shares of X at $30 USD on Nov 1, 2010, CAD forex rate on Nov 1/2010 = $1.20 Therefore Cost Basis is = $3600 CAD
- Bought 200 shares of X at $40 USD on Nov 1, 2016, CAD forex rate on Nov 1 2016 = $1.30. Therefor Cost Basis of these shares is $10,400 CAD. But you already have 100 shares from before, so actual cost basis of 300 shares is $14000 CAD. You keep the trade confirmation slips for your records.
- You now sell all 300 shares of X at $50 USD on July 1, 2024. CAD forex rate on July 1, 2024 is $1.44. Your disposition proceeds are thus $21,600 CAD.
- Your capital gain is $21,600-$14000 = $7600 on your Schedule 3 no matter what the T5008 says.

Anecdote: I had a relatively busy year in 2024 selling half a dozen securities. 4 of them had a T5008 Cost Basis that was far from correct.

1. In one case, it was a matter of the brokerage not subtracting ROC (Box 42) from Cost Basis on an annual basis all the way back to May 2006 when I first bought the stock. The brokerage Cost Basis was far too high because they did not subtract ROC from Cost Basis over the first many years. I used my lower Cost Basis regardless of what the T5008 said.

2. In another case, it was Pfizer stock which had spun off an entity in circa 2021 in which case it was up to the taxpayer to split the Cost Basis allocation in accordance with what Pfizer said the allocation was to each of the 2 succeeding stocks, or the taxpayer could use an election to keep the Cost Basis completely with Pfizer and assign zero Cost Basis to the spinoff. I had done the former while the brokerage made an erroneous assumption that I did the latter. Thus again, the brokerage Cost Basis was far too high.

3. In yet another case, I had bought a Canadian interlisted stock in USD in New York many years ago. It sat on the USD side of the account because the stock issued dividends in USD but when I sold it in 2024, I wanted to have the proceeds in CAD so I had the brokerage 'journal' the stock over to the CAD side of my account first. The Cost Basis they assigned to the stock used the forex rate on the date of the journal, not the forex rate in effect on the date I actually purchased the stock. How freaking stupid is that? So again, the brokerage cost basis was wrong.

Etc, etc... There are several, usually non-mainstream, reasons why a brokerage will get Cost Basis wrong. That is why the taxpayer is solely responsible for Cost Basis.

Final comment: It has been generally posted on internet forums in recent (10?) years that brokerages are doing a better job of accurate Cost Basis reporting/recording and in most cases, I find they have been accurate for 'run of the mill' transactions. Chances are for most people reading this post, there is reason to believe Cost Basis has been recorded properly. In which case, it is probably best to leave well enough alone for past tax filings, but there is no better time to start doing it right than right now in 2025 forward.

May 4, 2025
10:54 pm
Norman1
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AltaRed said

You are not doing your USD conversions correctly for capital (Schedule 3) transactions. There is no such thing as an annual average forex rate for capital transactions. The forex to be used is the one that is effect on the actual date of transaction (or date of settlement if one so chooses). There will always be one forex rate based on the day (days) of acquisition of the security and another forex rate based on the date of sale (or date of settlement) of the transaction. Annual forex rates never apply to capital sales.

I agree.

CRA was asked and replied that four conditions need to be met in order for use of an average annual, quarterly, or monthly exchange rate to be acceptable. Those conditions are not going to be met by sporadic dispositions of shares.

Acceptable Canadian dollar accounting is not recordkeeping in US$ and converting the US$ capital gain/loss on disposition to Canadian dollars. Unfortunately, it is as AltaRed described: Recording the Canadian dollar value of each transaction as it occurs, even when there is no actual currency conversion between US$ and Canadian dollars.

RBC Wealth: Foreign currency tax reporting has an example on page 2 where a disposition results in a US$500 capital gain but a $288 loss for Canadian tax purposes:

Sale of America Corp. Settlement date U.S.
dollars
Exchange
rate
Canadian
dollars
Proceeds of disposition Mar. 26 – Year Two $12,000 [A] 1.2013
[B]
$14,416
[A x B]
ACB Jan. 1 – Year One $11,500 [D] 1.2786
[E]
$14,704
[D x E]
Capital gain/(loss) - $500 - ($288)
May 5, 2025
2:32 am
zgic
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Thanks a lot AltaRed, I will go through your links. I convert CAD to USD during favorable times outside of the brokerage account and keep them in a USD account. Then I transfer it to the brokerage account.
Is there any reason for you to use 2006 as the base year?
I opened my margin account in 2018 and will start keeping a record for my cost basis from 2025. I will go back and try to do my cost basis per security for the past 2 years which are of more impact.
I can go back till 10 years and refile with CRA correct?

Thanks Norman1 for your inputs. For capital gains I will have to use the date of transaction for exchange rate.

May 5, 2025
5:52 am
Norman1
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The exchange rate to be used is the rate on the settlement date, not rate on the date the order filled.

If there wasn't an actual currency conversion, then the prescribed exchange rate is the Bank of Canada exchange rate. This is from Income Tax Folio S5-F4-C1, Income Tax Reporting Currency:

1.4 For a particular day after February 28, 2017, the relevant spot rate is to be used to convert an amount from one currency to another, where one of the currencies is Canadian currency is the rate quoted by the Bank of Canada on that day. If the Bank of Canada ordinarily quotes such a rate, but no rate is quoted for that particular day, then the closest preceding day for which such a rate is quoted should be used. If the particular day, or closest preceding day, of conversion is before March 1, 2017, the Bank of Canada noon rate should be used.

1.5 In cases where neither of the currencies involved in the conversion is Canadian currency, the relevant spot rate is derived by reference to the Bank of Canada rates to exchange Canadian currency for each of those currencies.

May 5, 2025
6:29 am
AltaRed
BC Interior
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It has been standard practice, and well documented, for CRA to accept either transaction date or settlement date for the basis of forex rate as long as one is consistent with one practice or the other for all transactions year after year. I have used transaction date for some 30-40 years because that is the "actual date of decision for making the purchase or sale" and that is when I have made the funds available for the purchase.

Settlement day is more logical in a corporate or institutional setting where money flow is being managed every single day, i.e. an institution may convert funds same day as payment is due (settlement). It ultimately does not matter and there is material on the internet from CRA, CPA, etc. saying that either methodology is acceptable. It matters even less these days with T+1 settlement versus T+3 settlement of years past.

You will note that T5008 slips use settlement date for date of transaction but I enter Transaction Date in Schedule 3 and have never heard 'boo' from CRA all these years. Again, consistency is key so that one is not caught cherry picking between the two for financial (taxation) benefit.

Zgic, there is nothing magical about 2006. I simply use that as a reference date in my examples and I have a habit of doing that since I came back to Canada in 2006 and date of entry set the new Cost Basis for my portfolio. My point is that I have Cost Basis records for securities going back to that 2006 entry date and brokerages at that time were not nearly as effective, efficient and correct in Cost Basis records. We, as investors, used spreadsheets and Bank of Canada daily (et al) forex rates to maintain our Cost Basis records. I still keep PDF copies of trade confirmation slips of stocks I bought back then and still hold as evidence to justify my Schedule 3 entries. I have never relied on the T5008 (a relative recent offering by brokerages) to populate my Schedule 3 entries.

I cannot advise on what you should do as regards getting your Cost Basis up to date, nor whether should you go back and refile/correct several years of past tax returns. I probably would let sleeping dogs lie and simply do it correctly going forward. Only you know whether to open that can of worms. What I would do however, is start with securities you still own and ensuring the Cost Basis is correct on those back to 2018 when you started this journey, so that when you sell them in 2025 and beyond, you have correct Cost Basis for every security you still own.

I do not know which brokerage you use but I suspect most mainstream brokerages are probably keeping your Cost Basis correctly if you have had normal trading activity, e.g. no corporate spinoffs, no journaling between CAD and USD side of accounts, no Canadian domiciled securities (ETFs) with year end non-cash capital re-invested distributions (some get this one right while others do not), ROC adjustments that lower Cost Basis (trusts such as ETFs, mutual funds, income trusts like REITs, etc). It is these latter things for which brokerages do not always get Cost Basis correct.

May 5, 2025
7:01 am
AltaRed
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A bit of a rant post here that Moderators may wish to toss, but in 30 years of investing and participating in financial forums, I think I have seen it all in terms of taxation knowledge, or lack thereof, when it comes to capital gains/loss calculations in non-registered accounts for taxation purposes. [None of this of course applies to registered accounts.]

In the earlier years before DIY investing became mainstream and/or online investing became readily available to 'everyone' who could walk and chew gum at the same time, there were far fewer retail investors in stocks, bonds, et al and far fewer transactions being made by retail investors. We talked to a full service broker by phone and often made funds available by cheque. Investors at that time were far fewer, and in my opinion, more likely to get capital gains/loss transactions more correct on their tax returns and/or had fewer transactions to revise/correct. More of us may have also had tax accountants to keep us on track rather than so much DIY tax filings via tax software/Netfile.

With the explosion of DIY online investing, availability of apps, electronic transfer of funds et al, anyone could and suddenly becomes an investor. Yet, at the same time, there has been either no (or inadequate) education being offered by the brokerages in terms of getting Cost Basis right, or investors simply are ignorant/naive of what has to be done to keep records for taxation purposes. How many people have actually read the CRA Capital Gains Guide, or the capital gains materials offered by TaxTips, or AdjustedCostBase.ca, or any number of brochures by financial institutions like RBC Asset Management?

Just like no one should get behind the wheel of a Ferrari before they have driver's training and a license, it is my view no investor should buy/sell capital property without first undertaking the appropriate education and training in taxation responsibilities that comes with responsible ownership of capital property (securities). Fortunately, this particular problem is limited to non-registered accounts, so it is not a total catastrophe, AND with brokerages in more recent times producing a T5008 and/or an annual capital transactions report that gets most of this right most of the time, the errors are not likely to be nearly as severe as they could be. Okay....rant over.

May 5, 2025
7:34 am
Lodown
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Thanks to all for the valuable information about T5008 slips (they do not always involve a Schedule 3 Capital gain or loss), currency conversion dates to be used for stock CG purposes, cost basis options when receiving company spinoffs, etc and finally a great rant from AltaRed......to which I would like to add....In this day of computerization, why don't tax slip issuers include the day's exchange rate along with foreign stock purchases/sales? And with so many mistakes with Adjusted Cost Base, why not include the statement, "While we strive for accuracy, the figures provided my contain errors.".

May 5, 2025
8:50 am
Norman1
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The back of the T5008 slip is supposed to include this:

Box 20
The amount in box 20 may or may not reflect your adjusted cost base (ACB) for the purpose of determining the gain or loss from the disposition of the security. You are required to make the adjustments, as needed, to the amount indicated in box 20, at the time of determining and reporting your gain or loss from the disposition.

The ACB in box 20 can also be off because investor had purchased the same shares through different brokerages and agents. Each broker and agent knows the cost of the shares purchased through them. But, there isn't an exchange of that private share cost info between them.

Brokerage hasn't made an error when it reports that the 100 shares sold through them cost $1,000 if the shares purchased through them cost an average of $10/share. The brokerage is not required to reach out and discover the shares the client had acquired through an employee stock purchase plan a decade before at an average cost of $6/share and is holding directly in the client's own name.

As far as foreign exchange rates, there isn't one acceptable exchange rate for a given day. CRA will accept a rate other than the prescribed Bank of Canada rate if certain conditions are met:

1.6 In certain situations, taxpayers are allowed to use an exchange rate other than the rate described in ¶1.4 and 1.5. In this regard, the CRA will generally accept, as the relevant spot rate for a particular day, a rate quoted by a source other than the Bank of Canada if it is:

  • widely available
  • verifiable
  • published by an independent provider on an ongoing basis
  • recognized by the market
  • used in accordance with well-accepted business principles
  • used for the preparation of the taxpayer's financial statements
  • used consistently from year to year by the taxpayer.

Each of the above conditions must be met in order for such a rate to be accepted. Examples of other sources of acceptable foreign exchange rates include Bloomberg L.P., Thomson Reuters Corporation and OANDA Corporation.

May 6, 2025
4:51 am
RetirEd
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The more I learn about the complex tax consequences of capital gains investing, the less I want to risk dabbling in it!

RetirEd

May 6, 2025
7:43 am
Wrayzor
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RetirEd said
The more I learn about the complex tax consequences of capital gains investing, the less I want to risk dabbling in it!  

It's not really that difficult under most investing circumstances. You keep track of transactions (buy/sell/dividend reinvestments) and the ACB calculations are simple math. Using multiple brokerages doesn't make for more complex record-keeping. Other wrinkles (FX, ROC, etc.) can easily be figured out in a few seconds with a Google search.

Yes, the tax code is a load to understand, but the vast majority of retail investors don't come close to touching the complex areas. I'm in agreement with AltaRed that uptake of education is sorely lacking. I think the brokerages provide a wealth of material but people don't use the resources available. A basic finance/tax test to open an account? It would probably work as well as the driving test does to make sure people operate motor vehicles (of any kind) properly.

May 6, 2025
9:41 am
Norman1
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A test is not going to help. People will find ways to pass the test without actually understanding the material.

Every full service broker I've dealt with had to take the Canadian Securities Course and pass the exam to be licensed. Some of them obviously knew less than I did back then and didn't really understand equity investing.

It wasn't until years later I learned that they were licensed as dealing representatives (salespeople) and not advising representatives (people who can legally give original investment advice).

May 6, 2025
9:59 am
zgic
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@AltaRed:
1. I use Questrade as a brokerage.
2. I assumed that the brokerage T5008 is correct. I thought the current softwares are better, which generate the T5008. I think they are wrong even on basic trades and since they are NOT RESPONSIBLE, they would NOT bother about it.
3. Now we are receiving the T5008 electronically. These electronic slips do not have a back page which Norman1 showed. If I had seen that bold heading saying that I am responsible for the ACB, I would have been aware.
4. I saw that my ACB was wrongly calculated and it was much less and hence it has resulted me in paying much more tax. CRA will not be concerned if I have paid more tax, but will only be concerned if I have paid less tax. Please correct me if I am wrong in this statement. Will CRA be bothered if I pay more tax? Now I have to show them my correct ACB to get my money back.
5. @AltaRed: Thanks for your rant and the links. I will try to use adjustedcostbase.ca. Question: As I understand I will have to keep records per security going forward for the ACB. Is adjustedcostbase.ca per security?

May 6, 2025
12:04 pm
Wrayzor
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Norman1 said
A test is not going to help. People will find ways to pass the test without actually understanding the material  

That was my (sarcastic) point. Same as there are drivers on the road who shouldn't be anywhere near a motor vehicle.

May 6, 2025
12:27 pm
AltaRed
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zgic said
@AltaRed:
4. I saw that my ACB was wrongly calculated and it was much less and hence it has resulted me in paying much more tax. CRA will not be concerned if I have paid more tax, but will only be concerned if I have paid less tax. Please correct me if I am wrong in this statement. Will CRA be bothered if I pay more tax? Now I have to show them my correct ACB to get my money back.
5. @AltaRed: Thanks for your rant and the links. I will try to use adjustedcostbase.ca. Question: As I understand I will have to keep records per security going forward for the ACB. Is adjustedcostbase.ca per security?  

If CRA knowingly knows you paid too much CG tax they would have queried you or adjusted your NOA to reflect the proper number. Likewise had you paid too little. The point is since you are expected to report the correct data on your tax return, they don't knowingly know otherwise. Clearly if you want to recover 'overpaid' capital gains you will have to go back and issue T1As for all the incorrect Schedule 3s of past tax years. Whether you do, or not, may be a function of your time vs funds to be gained.

You may find some of your adjustments will be negative as well as positive. Rarely would errors be all in one direction. If you correct one, you probably would need to correct all of them, positive or negative.

ACB has to be tracked on a security basis until such time you sell all of it, and records kept for 6? years thereafter. You would most definitely have different line items in adjustedcostbase.ca for each security. I do not use that service so cannot comment directly.

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