via The Royal Canadian Mint - Performance Update

In the performance update for the Royal Canadian Mint's Exchange-Traded Receipts, they mention that you can swap receipts for bullion, with no capital gains. I'm wondering whether you can swap doré for cash without being subject to revenue.

Both Sprott and the Mint created the same type of investment vehicle around the same time, they both would have had reason to acquire tonnes of gold from producers. They had no gold to begin with and were required to buy straight out of the mines. So my guess is they created swap arrangements, as this is allowed under tax law.

GBN.V could only have supplied around 4-2/3 tonnes per year after costs, and would have been a small contributer to the overall total at Sprott, but could have supplied the MNT. Sprott made deals with numerous small producers, all under the guise of lending. Gold notes or Gold-linked notes.

Both Sprott and the Mint raised hundreds of millions, by now Sprott's ETF greatly exceeds the original plan.

http://www.reserves.mint.ca/Gold/Content/documents/en/Q2_2015_Performance_Update_Gold.pdf