Quote Originally Posted by SBQ View Post
Shorting Uber shares directly is simplistic (providing your broker has a pool of shortable shares ; note not all brokers are the same and you'll find the NZ brokers most likely don't have access or an allotment of shares to allow for short position). In terms of FIF, an account balance is always determined during a short position so therefore, tax by FIF will still apply.
Am surprised that FIF rules would apply to a short position. Is this correct? I would argue that at no time do you have "a direct interest in a foreign company" as defined by EX30 of the Income tax Act. When the broker closes out the short position the shares are returned to the broker's pool of shortable stock. One is never listed as the holder of the stock.

Also, if one was to say, go short in XYZ Inc in May 2017 at $1000 a share and cover in June 2020 at $100 a share, how exactly would that be taxed under FIF rules? With there being a margin loan, short borrowing costs, responsibility to pay dividends to the long party etc, and never actually owning the stock, surely it's more akin to a Financial Arrangement?