Respecting the application of s. 49(1) to the writing and sale on an exchange of a naked call option and the reporting of the “cost” of the option on the T5008 issued by the securities dealer, CRA stated:
[W]here an option is capital property … subsection 49(1) … provides (subject to the application of subsections 49(3) and 49(3.1) … and the exceptions in paragraphs 49(1)(a) to (c) …) that the granting of an option is equivalent to a disposition of property having an adjusted cost base of nil … [so that] there is no need to allocate cost to the option.