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This wasn't stock, it was units in a Canadian royalty trust.

If you check the information memo for the takeover transaction, you'll find Canadian income tax considerations disclosure. It says the value of the distribution of cash and shares in exchange for units is treated as ordinary income in its entirety for Canadian tax purposes, and that non Canadian unit owners will be subject to Canadian withholding tax on the full amount of the distribution (which means no basis recovery in determining Canadian tax deducted from distribution). Non-Canadian unit holders were advised to talk to their tax advisors and consider selling their units on the Toronto or NY stock exchange ahead of the closing.
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