Respecting arrangments for the monetization of shares of public corportions, CRA stated:
Ruling F in document 2007-0246461R3 provides that the amounts that will be received or paid by the corporations in settlement of the rights or obligations flowing from the forward contract will be on account of capital.
We are now of the opinion that the return that was included in the forward contract (through an increase of the forward price) would constitute income rather than capital. It should be noted that the agreement that was designated as a forward contract in document 2007-0246461R3, now appears to us to be more in the nature of an equity swap.