You are correct! But the thing to keep an eye on is whether your broker charges the 15% IRS WHT anyway - which they should not do but who knows if they are adequately informed by HOT.UN re the RoC characterization. The problem with the IRS WHT is that once they ding you for this amount - there is no retroactive reimbursement. I "lost" over $800 in 2019 due to BMO withholding 15% every month - and then not refunding when the  distributions were declared primarily Return of Capital on the T5013 form. A real headache! One of the reasons I sold this holding in early 2021.

Investorguy123 wrote: Thanks, 100 % ROC, would be a good news to me, no 15% withholding tax. Because it is 100% ROC, that means there is no tax involved anyway whether you file tax return or not. But you should include it to reduce the cost when you sold the units.