Australia resident individuals · rules as at October 2026

The tax year

1 July to 30 June. If you lodge your own return, it is due by 31 October.

Selling at a gain

Selling shares is a capital gains tax (CGT) event. It happens when you enter the contract to sell, so the trade date counts, not the settlement date. Your net capital gain for the year is added to your other income and taxed at your ordinary rates. There is no separate CGT rate.

The 50% discount. If you are an Australian resident individual and you held the shares for at least 12 months, only half the gain is added to your income. The day you bought and the day you sold don’t count towards the 12 months. Complying super funds get a one-third discount; companies get none. Foreign and temporary residents lose the discount on gains after 8 May 2012.

The 16% rate falls to 15% from 1 July 2026 and to 14% from 1 July 2027 (legislated in March 2025). The Medicare levy is generally 2% on top.

Selling at a loss

A capital loss can only reduce capital gains, never your salary or other income. Losses are taken off gains before the 50% discount is applied, and any you can’t use carry forward with no time limit.

What the shares cost you

The cost base is what you paid plus incidental costs such as brokerage. If you bought the same shares more than once, each purchase is its own parcel with its own date and price. When you sell part of a holding and can tell which parcels you sold, those are the ones; otherwise the ATO accepts your choice of which parcels were sold — first in, first out is one option, not a rule. Keep records for at least five years after the sale, longer if a carried-forward loss depends on them.

Dividend reinvestment. A reinvested dividend is still taxed as income that year, and the new shares are a new parcel, bought on the day they were issued at the amount of the dividend.

Foreign currency. For shares bought or sold in another currency, the price and costs are converted to Australian dollars at the exchange rate on the day of each transaction — so a currency move between buying and selling is part of the gain or loss.

Dividends and franking credits

An Australian company that has paid tax can attach franking credits to its dividends. You include the dividend plus the credit in your income (the “gross-up”), then get the credit back as a tax offset. If your offsets are more than the tax on your income, resident individuals get the excess refunded.

The 45-day rule. To use the credits you must hold the shares “at risk” for at least 45 days (90 for some preference shares), not counting the days you bought and sold. The rule doesn’t apply if all your franking credits for the year come to less than $5,000.

Selling and buying back: wash sales

Australia has no fixed waiting period. Instead, the ATO’s ruling TR 2008/1 says that selling shares to make a loss and buying the same or substantially the same shares back, with no real change in what you own, can be treated as a scheme to get a tax benefit, and the loss cancelled. The ruling’s examples treat a same-day or next-day buy-back as a wash sale. The ATO matches share registry and exchange data to find them, and has warned about them ahead of the end of the financial year.

Shares listed outside Australia

If you live in Australia, gains on shares listed overseas are taxed here in the same way, in Australian dollars. Dividends are taxed here too, but the company’s country usually takes a share first (withholding tax). You can generally claim that back against your Australian tax as a foreign income tax offset: up to $1,000 a year without further calculation, more with a calculation of your offset limit. The offset is not refundable.

Rates for Japan and the European countries are from PwC’s Worldwide Tax Summaries, reviewed mid-2026; the US, Canadian, UK, Hong Kong and Japanese claim procedures are from those governments’ own pages. Brokers apply the treaty rate only if they hold your paperwork.

Gains in the company’s country. As a non-resident you are generally not taxed by the US, Canada, the UK, Hong Kong or Germany on gains from ordinary listed shares. The exceptions are mostly companies whose value comes chiefly from land, and large stakes.

US estate tax. Shares in US companies count as US property when their owner dies, wherever the broker is. For someone who isn’t a US citizen or resident, the estate must file a US estate tax return (Form 706-NA) if their US assets are worth more than US$60,000. Australia has an estate tax treaty with the US, dating from 1953, which can give a larger, pro-rata exemption; executors claim it on that return. It is one of the less-known costs of holding US shares directly, and worth raising with whoever helps with your will.

Inside super

Investment earnings inside a complying super fund in accumulation phase are taxed at 15%, and gains on assets held more than 12 months at an effective 10%. Self-managed funds hold shares directly under the same rules.

In Trendentum: set your tax residency to Australia under Account settings and enter the Bought date on each purchase. The tax notes then count each parcel towards the 12-month line separately, and give the date each one passes it.

Sources: ATO — CGT discount, resident tax rates, losses on shares, cost base, franking tax offsets, TR 2008/1, foreign income tax offset; IRS — W-8BEN, Form 706-NA; CRA — NR301; Australian Treasury — estate and gift tax treaties; PwC Worldwide Tax Summaries.

United States resident individuals · rules as at October 2026

The tax year

The calendar year. The return is due on 15 April (the next business day if that falls on a weekend or holiday); Form 4868 gives an automatic six-month extension to file, but not to pay.

Selling at a gain

Shares held more than one year give a long-term gain, taxed at 0%, 15% or 20% depending on your taxable income. Held a year or less, the gain is short-term and taxed as ordinary income.

Net investment income tax. A further 3.8% on investment income, gains included, above modified adjusted gross income of $200,000 (single) or $250,000 (married filing jointly). These thresholds are not indexed for inflation.

Selling at a loss

Losses offset gains in full, then up to $3,000 a year ($1,500 if married filing separately) of other income. Anything left carries forward to later years.

What the shares cost you

If you don’t identify which shares you sold, the IRS treats the first ones bought as the first sold (FIFO). You can tell your broker to sell specific lots instead. Brokers report the proceeds, and for shares bought after 2010 usually the cost and holding period too, on Form 1099-B.

Dividends

“Qualified” dividends are taxed at the long-term capital gains rates; others at ordinary rates. A dividend is qualified only if you held the shares for at least 61 days in the 121-day window that starts 60 days before the ex-dividend date (other conditions apply to the company).

Selling and buying back: the wash sale rule

If you buy substantially identical shares within 30 days before or after selling at a loss, the loss is disallowed for now and added to the cost of the new shares, so it comes back when those are sold.

Shares listed outside the US

Foreign tax withheld from dividends can usually be claimed as a foreign tax credit. If it is all passive income reported on a 1099, and no more than $300 ($600 on a joint return), you can claim it directly without Form 1116.

Accounts that change the answer

2026 contribution limits: 401(k) $24,500 (plus $8,000 catch-up from age 50, $11,250 at ages 60–63); traditional and Roth IRA $7,500 (plus $1,100 from age 50). Inside these accounts, trades and dividends aren’t taxed each year; traditional accounts are taxed when withdrawn, Roth accounts generally not.

In Trendentum: with tax residency set to the United States, the tax notes count each purchase towards the one-year line.

Sources: IRS — Topic 409, capital gains and losses, Rev. Proc. 2025-32 (2026 figures), Topic 559, net investment income tax, 1099-DIV instructions, Schedule D instructions, 2026 retirement limits, foreign tax credit.

United Kingdom resident individuals · rules as at October 2026

The tax year

6 April to 5 April. For 2025–26, a paper Self Assessment return is due by 31 October 2026 and an online one, with the tax, by 31 January 2027.

Selling at a gain

The first £3,000 of gains each year is free of Capital Gains Tax (the annual exempt amount). Above that, gains on shares are taxed at 18% within the basic-rate band and 24% above it — the rates since 30 October 2024, unchanged for 2026–27.

Selling at a loss

Losses are set against gains in the same year first; what is left can be carried forward, as long as you report the loss within four years of the end of the tax year you made it in.

What the shares cost you: the matching rules

Shares of the same company are matched in a fixed order: first with shares bought the same day, then with shares bought in the following 30 days, and only then with the “section 104 pool” — all your earlier purchases averaged together. The 30-day rule is what stops “bed and breakfasting”: sell and buy back within 30 days and the sale is matched to the new shares, not the old.

Dividends

The first £500 of dividends a year is tax-free. From 6 April 2026 the rates above it are 10.75% (basic rate), 35.75% (higher rate) and 39.35% (additional rate) — the first two up two points from 2025–26.

Buying UK shares

Most purchases of UK company shares pay 0.5% stamp duty (as Stamp Duty Reserve Tax on electronic trades). Since 27 November 2025, shares in companies that have newly listed on a UK market are exempt for their first three years.

Accounts that change the answer

An ISA takes up to £20,000 a year, and gains and dividends inside it are tax-free. From 6 April 2027, no more than £12,000 of that can go into a cash ISA for savers under 65; the overall £20,000 stays.

In Trendentum: with tax residency set to the United Kingdom, the tax notes show the tax year but no holding-period line, because the UK has none for shares.

Sources: GOV.UK — CGT rates and allowances, tax on dividends, how ISAs work, HS284 shares and CGT, losses, tax when you buy shares, Self Assessment deadlines.

Canada resident individuals · rules as at October 2026

The tax year

The calendar year. The return and any balance owing are due on 30 April (15 June to file, but still 30 April to pay, if you or your spouse were self-employed).

Selling at a gain

Half of a capital gain is taxable, added to your income at your ordinary rates. The increase to two-thirds proposed in 2024 was cancelled on 21 March 2025. There is no holding period: a gain is a gain however long you held the shares.

Selling at a loss

Half of a capital loss is an allowable loss, usable only against taxable capital gains. Unused losses can be carried back three years or forward indefinitely.

What the shares cost you

Identical shares are pooled: the adjusted cost base is the average cost of all you hold, recalculated at each purchase. Selling some doesn’t change the average cost of the rest.

Selling and buying back: superficial losses

If you, or someone affiliated with you, buy the same shares within 30 days before or after selling at a loss, and still hold them 30 days after the sale, the loss is denied and generally added to the cost of the new shares.

Dividends

Dividends from Canadian companies are grossed up and then given a dividend tax credit, to allow for tax the company has paid. For eligible dividends the gross-up is 38% and the federal credit 15.0198% of the grossed-up amount; for other Canadian dividends, 15% and 9.0301%. Provinces add their own credits. Foreign dividends are taxed in full, with a foreign tax credit (Form T2209) for tax withheld abroad.

Accounts that change the answer

The TFSA limit is $7,000 for 2026; gains and income inside it are tax-free. The RRSP limit is $33,810 for 2026 (18% of last year’s earned income up to that); tax is deferred until withdrawal. Under the Canada–US treaty, US dividends paid into an RRSP are generally exempt from US withholding; in a TFSA they are not — widely applied by brokers, though not stated as such on a CRA page.

Sources: CRA — T4037 capital gains, capital losses and superficial losses, T5 guide (dividends), RRSP and TFSA limits, filing dates; Prime Minister’s Office, 21 March 2025.

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