15 February 2012 External T.I. 2011-0426531E5 - Exchange of Gold Bullion for ETR -- summary under Disposition

Based on the Exchange Traded Receipts of the Royal Canadian Mint representing undivided legal and beneficial interests in gold bullion and on the statement in IT-387R2, para. 4 that an exchange of gold certificates for gold bullion is not considered to be a disposition, the exchange of such ETRs for gold bullion might not be considered to be a disposition. However, a redemption of ETRs for cash likely would be a disposition.