When calculating adjusted cost base, it’s important to use the correct ordering of the transactions. In some cases it may not matter – for example, in a sequence of multiple buy transactions, the order within that sequence will not affect the final result. But where buy transactions are interlaced with sell transactions, the order matters.
The correct order to use is the chronological order. A transactions that occurs first (based on the settlement date if applicable) should be applied towards the ACB first. When transactions occur on distinct dates, there’s a lower chance of confusion. But when multiple trades (or types of distributions) occur on the same date, the ACB calculation process becomes more prone to errors.
Let’s look at a simple example. Assume that the following transactions take place for BCE, all on Monday, November 3rd, 2014 (with a settlement date of Thursday, November 6th, 2014):
- At 9:30AM you buy 100 shares at a price of $51.45 per share
- At 11:00AM you sell 25 shares at a price of $52.95 per share
- At 3:30PM you buy 75 shares at a price of $55.25 per share
In this example we’ll assume that there are no brokerage commissions for simplicity. The correct, chronological order of the transactions is: 1, 2, 3. The ACB will be calculated as follows, assuming that your ACB for BCE is initially zero before these trades occur:
Settlement Date | Transaction | Shares Bought or Sold | Price Per Share | Share Balance | ACB | ACB per Share | Capital Gain (Loss) | |
---|---|---|---|---|---|---|---|---|
1. | 2014-11-06 | Buy | 100 | $51.45 | 100 | $5,145.00 | $51.45 | – |
2. | 2014-11-06 | Sell | 25 | $52.95 | 75 | $3,858.75 | $51.45 | $37.50 |
3. | 2014-11-06 | Buy | 75 | $55.25 | 150 | $8,002.50 | $53.35 | – |
With the correct transaction order, a capital gain of $37.50 occurs from the sell transactions.
Now, let’s mix up the transaction order as follows: 1, 3, 2. Now the two buy transactions will now be factored into the adjusted cost base before the sell transaction. This results in the following:
Settlement Date | Transaction | Shares Bought or Sold | Price Per Share | Share Balance | ACB | ACB per Share | Capital Gain (Loss) | |
---|---|---|---|---|---|---|---|---|
1. | 2014-11-06 | Buy | 100 | $51.45 | 100 | $5,145.00 | $51.45 | – |
3. | 2014-11-06 | Buy | 75 | $55.25 | 175 | $9,288.75 | $53.08 | – |
2. | 2014-11-06 | Sell | 25 | $52.95 | 150 | $7,961.79 | $53.08 | ($3.21) |
As you can see, the capital gain of $37.50 from the sell transaction is now transformed into a capital loss of $3.21. Factoring the incorrect transaction ordering into the ACB calculations results in an incorrect capital gain. Note that the final ACB and ACB per share are also incorrect. When the balance of the shares are eventually sold, the total capital gain (or loss) will remain the same in the case, regardless of the transaction order. However, the allocation of capital gains or losses over time will differ.
Please also note that the above calculations assume the transaction are on capital account, as opposed to income account. If you consistently have a large number of transactions for a security on a single day, the CRA may deem the transactions to be on income account due to a high transaction frequency, fast turnover rate, and short period of ownership. In this case, you cannot claim the gains and losses as capital gains and losses, and adjusted cost base does not apply.
In cases where frequent trading occurs and where a capital loss has occurred, the superficial loss rule may apply. In this case, all or part of the capital loss may be denied.
When using AdjustedCostBase.ca for calculating ACB, it’s also important to pay attention to transaction order. For transactions with distinct dates, the ordering will be handled automatically – transactions with earlier dates will be factored into the ACB before transactions with later dates. But users will need to be careful in cases where multiple transactions occur on the same date for a particular security.
By default, transactions for the same security with identical dates will be ordered in the same order the transactions were entered on AdjustedCostBase.ca. So the easiest thing to do is to enter the transactions in the order they occur. But users are also able to rearrange the transaction order after the transactions have been inputted.
Let’s look at the example above, inputted into AdjustedCostBase.ca, with the incorrect transaction order (1, 3, 2):
In this case a capital loss of $3.21 occurs. AdjustedCostBase.ca provides you with the ability to correct the transaction order. In the case where multiple transactions occur on the same date for a particular security, an “Order” column will appear in the transaction list, with arrows allowing you to move transactions up or down.
To correct the transaction order, we can click on the down arrow for transaction 3 (or, it could be corrected by clicking on the up arrow for transaction 2).
After doing so, the adjusted cost base and capital gain are corrected:
When using AdjustedCostBase.ca, the simplest thing to do is to add transactions occurring on the same day in the order they occur (i.e., enter the first transaction first). This way, the transaction order will be correct from the get go, and you won’t need to rearrange the order afterwards.
You’re only able to change the order among transactions that occur on the same day, for the same security. The order for transactions occurring on different days is determined based on chronological order. Also, if an options transaction is opened and closed on the same day, the closing portion must occur after the opening portion (you will not be allowed to move the closing portion such that it’s earlier than the opening portion).
What do we do for same day transactions which are performed by the fund management and they don’t tell the investor the TIME of the transactions?
Stuart,
Are any of these transactions sales? If not, then the order likely does not matter. For example, with multiple purchase transactions the resulting ACB at the end of the day will be the same no matter how the transactions are ordered.
Yes, some are indeed sales … the result of my making withdrawals the same day as they do the reinvestments. 🙁
Stuart,
You may want to inquire with the fund company in that case. The capital gain/loss could be different depending on the ordering. In the long run (over the entire time you hold the fund) the total capital gains should be the same no matter what order you use, but the order can have the effect of shifting gains forward or backward in time.
OK … that will solve that issue … As strange as it seems it will be better for me to have capital gains earlier until 2019. No pensions started rolling in until then! 🙂 I’m still waiting for OAP to get their act together and approve my app. 5 months so far!
Thanks for the guidance 🙂
I once heard or read somewhere that, as opposed to what the above article says, that according to CRA, when all the transactions for the same security happen on the same day, buys come first and sells come after. This may not be true, particularly as the article above does not agree.
But one thing that could support the buys coming first is that there is no place that I can see on the confirmations where the time of day appears. Therefore, if I get a CRA audit, which to me is the whole focus of getting it right, I’m thinking that they won’t know which came first. So, unless they have a way of knowing which came first, it could be easier for them to arbitrarily assume that the buys come first. Also, at this point in time, concerning the past, in many if not most cases, I don’t know myself which came first. Any comments?
As per David Morgen’s comment above, I too recall something where the CRA will consider buys before sells when trades are made on the same date. But, I am coming from the perspective of a managed account, where the trades are all block orders and are allocated at the end of the trading day in a batch process, and don’t appear in the client accounts until the following day.
In that case, there is no possible way for the client to know which trade was posted first, since they were probably all sent to market in two separate block orders. So, it would make sense for the buy to be counted first.
Are there any recommendations in this regard?