Ian Caines, Chris Van Loan, "Character Conversion Transactions and Synthetic Disposition Arrangements Updated", Corporate Finance, Volume XIX, No. 1, 2013, p. 219.

Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Derivative Forward Agreement
Economic exposure requirement (p. 2198)

…before a sale agreement will be considered to be a DFA [derivative forward agreement], the agreement...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Synthetic disposition arrangement
One-sided v. two-sided test (p. 2200)

One interesting question that is not fully resolved (but that is highlighted by the inclusion of an...

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