CRA considers that “income” for FTC Treaty purposes includes taxable capital gains

Unlike many other Treaties, the double taxation article of the Canada-Brazil Treaty refers to Canada allowing a foreign tax credit for Brazilian income tax on "income," rather than "income or gains," which may be taxed in Brazil.  However, CRA accepts that "income" includes taxable capital gains.  Accordingly, a Canadian company which has sold its shares of a Brazilian company is allowed a foreign tax credit, against its Canadian income tax on that gain, for the Brazilian gains tax (notwithstanding that under Canadian domestic principles, that gain may be considered to be from a Canadian source).

Neal Armstrong.  Summary of 13 January 2014 T.I. 2013-0512581E5 under Treaties – Art. 24.