kkgd- yes I'm aware of the nuts and bolts of it but the really finer points are for the accountants. I do know it only applies to losses and not gains. I have a similar situation I'm contemplating right now with some canroyals. Tax law can sure be a pain at times. I'd hate to try and advise anyone to try such a thing on a sub penny like this one. Volatility can be a significant factor.