Re departure tax: what if deemed disposition from stocks resulted in capital losses and there are no gains from prior years to absorb the loss? Can I use the original cost, instead of the FMV, which is lower than the original cost for sales in the future? I see that the Canada-US tax Treaty allows taxpayers to elect for U.S. tax purposes a deemed disposition of property subject to the deemed disposition rule in Canada, my understanding is if I do NOT elect, I should be able to use the original cost for future sales. Could you please confirm whether my understanding is correct? Thank you very much for your time. I sincerely appreciate it.
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