Ian Gamble, "Income from a Business or Property: General Principles and Current Issues", 2014 Conference Report, Canadian Tax Foundation, 5:1-32

Share investments potentially a business (pp. 5:10-15)

[C]onsolidated Mogul's chief task in the relevant years was the development and management...

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Break fees referable to pre-acquisition agreement (pp.5:23-24)

Break fees arise in the public corporation marketplace. They are routinely...

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[E]arlier decisions made in the context of option agreements are helpful and persuasive. The courts have looked to the nature of the property...

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CFA holding company can hold shares of CFA subs as an investment business (p. 5:19)

[A] top-tier holding affiliate in a foreign country may have...

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