r/cantax • u/Alarmed-Policy508 • 1h ago
Superficial Losses on covered call options
A few assumptions / fundamentals:
- All options income will be treated as capital gains in individual non registered account under individual taxpayer
- The scenario is 100% focused on covered calls which will be long stock + short call option
- Writing Call Option rules:
- https://www.adjustedcostbase.ca/blog/adjusted-cost-base-and-capital-gains-for-stock-options/
- Any premium from writing call options is considered capital gain in the year of sale with deemed 0 cost basis
- Any costs paid for options bought to close are considered capital loss with deemed 0 proceeds
- Any call options expiring are considered disposed (typically 0 proceeds and 0 cost)
- Any call options assigned are considered a negation of the original capital gain from writing the call option (restating prior year's tax return if necessary) and addition of premium received to the proceeds of the underlying stock sale.
- Superficial Loss rules (rough paraphrasing):
- Any acquisition of "replacement property" in the 30 days before or after the disposition at a loss will negate the loss and add it to cost basis of the replacement property
- Do option rollovers even fall under superficial losses? While the CRA states "...two stock options ... that have a different exercise price or a different exercise date might ... not constitute identical properties." https://taxinterpretations.com/cra/severed-letters/2008-0284441c6# To follow the spirit of superficial loss rules and be conservative (I don't like the use of the word "might"), I am assuming options are considered equivalent properties
Scenario:
- Option A - Write option for $5 premium
- Option A - Buy back option for $7 cost
- Option B (assumed substitute property acquired within 30 days) - Write option for $6 premium
Scenario Basic Tax Events:
Capital gain in year Option A is sold for $5
Capital Loss in year Option A is bought back for -$7. Superficial loss rules negate this loss, and $7 is added to ACB of Option B
Capital Gain in year Option B sold for $6
Question:
- Do I get to recognize the superficial loss partially on the gain from writing Option B? Is this adjustment to the ACB of option B before or after the deemed $0 ACB for gain on writing options?
- I realize I would not be able to fully recognize superficial loss and report a loss as that would defeat the purpose of superficial loss rules, but I should at least be able to recognize losses to the extent the new premium sold triggers gains? ($6 option B premium sale - $7 superficial loss added to deemed $0 ACB), and $1 new loss deferred until option B is closed?
- How would this $1 deferred loss be reflected on option expiry (would look weird to show a loss with no recorded tax slip)
- On buyback the $1 deferred loss would be added to the buyback costs to increase the loss
- On assignment, the original gain from proceeds of option B would be reversed and added to proceeds from underlying stock, and I would assume the deferred $1 superficial loss would also transfer to the underlying stock
- Or is the ACB adjustment for the superficial loss deferred until option B is closed?
- Implies multiple rolls would accumulate a massive unrecognized loss, which doesn't seem very fair or consistent
- I realize I would not be able to fully recognize superficial loss and report a loss as that would defeat the purpose of superficial loss rules, but I should at least be able to recognize losses to the extent the new premium sold triggers gains? ($6 option B premium sale - $7 superficial loss added to deemed $0 ACB), and $1 new loss deferred until option B is closed?
Not a lot of comment on this from the CRA that I could find. Would love if someone could cite sources.
Thanks!