Principal Issues: Whether the proposed transactions qualify for the butterfly exemption found in paragraph 55(3)(b).
Reasons: See below.
Reasons: Wording of the Act and previous positions.
Principales Questions: Whether subsection 80.6(1) will apply to the scenario presented.
Position Adoptée: Question of fact.
Raisons: Wording of the provision.
Principal Issues: Is the value of an “excess deposit” in a taxpayer’s AgriInvest Account considered a “net income stabilization account” under subsection 110.6(1.1) and therefore deemed nil for purposes of the capital gains deduction?