An investor holds shares of Corporation Y in street name. His shares of Corporation Y listed on the TSX are exchanged by a broker, in an off-market transaction as required by securities regulations, and effected through a log or journal entry ("entrée dite journal"), for identical shares which are listed on the NYSE, so that the investor's shares pass from a Canadian to an American account. After quoting IT-448, para. 9, 14, CRA stated (TaxInterpretations translation):
[W]e are of the view that since the rights and privileges attaching to a share of Corporation Y quoted on the New York Stock Exchange are the same as those attaching to a share of Corportion Y quoted on the Toronto Stock Exchange, the exchange of a share of quoted on the Toronto Exchange for a share of Corportion Y quoted on the New York Exchange would not constitute a disposition for purposes of the ITA.