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

Summary Under
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a)
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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Summary Under
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Contracts
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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Summary Under
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Options

[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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Summary Under
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(a) - Subparagraph 95(2)(a)(ii) - Clause 95(2)(a)(ii)(B)
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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