Administrative Policy
2 December 2014 CTF Roundtable, Q. 1
Embedded right. Does the first fact pattern in the Explanatory Notes under the heading "Example – Exchangeable Shares", involving a share of a...
Articles
Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016
The draft DFA amendment erroneously refers to an obligation that is “capital property” rather than an “obligation.”
Raj Juneja, "Taxation of equity derivatives", 2015 CTF Annual Conference paper
Previous forward agreements engaging the rule (pp. 17:14-15)
...Prior to the introduction of the rules, many mutual funds were entering into...
Edward Miller, Matias Milet, "Derivative Forward Agreements and Synthetic Disposition Arrangements", 2013 Conference Report, (Canadian Tax Foundation), pp 10:1-50
Targeted mutual fund forward sale agreements (p. 10:2)
Many mutual funds (both mutual fund trusts and mutual fund corporations…) used forward...
Ian Caines, Chris Van Loan, "Character Conversion Transactions and Synthetic Disposition Arrangements Updated", Corporate Finance, Volume XIX, No. 1, 2013, p. 219.
Economic exposure requirement (p. 2198)
…before a sale agreement will be considered to be a DFA [derivative forward agreement], the agreement...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Synthetic disposition arrangement | 181 |
Jack Bernstein, "Exchangeable Shares and UPREITs Are at Risk in Canada", Tax Notes International, 20 May 2013, 783
The recent Canadian federal budget of March 13, 2013, contains a provision to prevent the conversion, through the use of derivative contracts, of...
Finance
Paragraph (b)
Subparagraph (b)(iii)
Articles
Nigel P.J. Johnston, Roger E. Taylor, "Taxation of Hedges and Derivatives: Recent Developments", 2016 Conference Report (Canadian Tax Foundation), 13:1-36
Potential application of pre-amendment DFA definition to currency forwards (pp. 13:15-16)
A currency forward locks in the exchange rate for the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Timing | 731 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges | 319 |