Zalupski’s prepaid variable forward — cash now, no disposition
Does not transferSay no and move on. It needs a liquid, publicly traded, concentrated position and a dealer willing to write the contract against it. There is no such position here. And even if there were, the Canadian treatment is hostile to the whole point: where a monetisation transfers substantially all the risk of loss and opportunity for gain, the CRA has generally treated it as a disposition — which removes exactly the feature that makes the instrument attractive.
Worth saying clearly because the mechanic is seductive in write-ups like this one: most billionaire liquidity technique needs scale, a US domicile, or a listed stock. Two of the three are unavailable to you and the third does not exist.