A client of a brokerage goes long a futures contract on a particular Government of Canada bond series and subsequently closes out the position by establishing the opposite position on the same contract, namely a short position after, in the meantime, having posted or received amounts based on changes in the contract price and the corresponding maintenance margin requirements. In the particular situation, he realizes a gain of $2,600, being the appreciation in the futures price multiplied by the number of contracts in his long position, on closing out that position. What amount should be disclosed as the "proceeds of disposition or payments" in Box 21 of the T5008 slip? After stating that a "long or short position in a CGB contract … is a ‘security’ under paragraph (f) of the definition … [in Reg.] 230(1), CRA stated:
[T]he amount to be entered in Box 21 of the T5008 slip entitled "Proceeds of disposition or settlement amount" is $2,600 which is the total proceeds realized by your client as a result of the liquidation of his open position in the 5 CGB contracts. In addition, we are of the view that the amount to be reported in Box 21 could be a negative amount in a situation where the liquidation of a particular open position in a CGB contract would result in a loss to the holder.