Nigel P.J. Johnston, Roger E. Taylor, "Taxation of Hedges and Derivatives: Recent Developments", 2016 Conference Report (Canadian Tax Foundation), 13:1-36

Summary Under
Tax Topics - Income Tax Act - Section 9 - Timing

Timing of employer loss recognition on hedge of phantom unit obligations (pp. 13:9-10)

Corporate employers may create phantom stock plans and...

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Summary Under
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges

Potential treatment of a dynamic hedge as on capital account (pp. 13:11-12)

A static hedge is one that does not have to be rebalanced as the price...

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Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Derivative Forward Agreement - Paragraph (b) - Subparagraph (b)(iii)

Potential application of pre-amendment DFA definition to currency forwards (pp. 13:15-16)

A currency forward locks in the exchange rate for the...

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