Capital Loss v. Loss

Cases

Panda Realty Ltd. v. MNR, 86 DTC 1266 (TCC)

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Newmont Canada Corporation v. Canada, 2012 DTC 5138 [at 7292], 2012 FCA 214

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus testimony sufficient to "demolish" assumptions 149
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) 99
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) interest was bad as settlement proceeds not allocated to it 212

Magicuts Inc. v. Canada, 2001 DTC 5665, 2001 FCA 332

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Easton v. The Queen, 97 DTC 5464 (FCA)

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R. v. Mara Properties Ltd., 96 DTC 6309, [1996] 2 S.C.R. 161

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Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) inventory character flowed through to parent on wind-up 107

United News (Wholesalers) Ltd. v. The Queen, 94 DTC 6508 (FCA)

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Millford Development Ltd. v. The Queen, 93 DTC 5052 (FCTD)

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The Queen v. Mandryk, 92 DTC 6329 (FCA)

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Easton v. The Queen, 92 DTC 6218 (FCTD), aff'd 97 DTC 5464 (FCA)

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Flexi-Coil Ltd. v. The Queen, 92 DTC 6047 (FCTD)

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Vine Estate v. The Queen, 89 DTC 5528 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) shareholder benefit where benefit on sister corp 185
Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(2) 31

Morflot Freightliners Ltd. v. The Queen, 89 DTC 5182 (FCTD)

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Le Bel v. The Queen, 87 DTC 5154, [1987] 1 CTC 259 (FCTD)

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H.Y. Louie Co. Ltd. v. The Queen, 86 DTC 6228, [1986] 1 CTC 499 (FCTD)

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Isaac Meisels Investments Ltd. v. The Queen, 85 DTC 5029, [1985] CTC 7 (FCTD)

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Factory Carpet Ltd. v. The Queen, 85 DTC 5464, [1985] 2 CTC 267 (FCTD)

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Saskatchewan Co-Operative Credit Society Ltd. v. The Queen, 84 DTC 6225, [1984] CTC 628 (FCTD), aff'd 85 DTC 5599 [1986] 1 CTC 53 (FCA)

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The Queen v. Lalonde, 84 DTC 6159 (FCTD), aff'd 89 DTC 5286 (FCA)

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The Queen v. Malone, 82 DTC 6130, [1982] CTC 145 (FCTD)

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Tax Topics - General Concepts - Tax Avoidance 39

Tamas v. The Queen, 81 DTC 5150, [1981] CTC 220 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges individual's losses on silver futures trading on income account 75

Paco Corp. v. The Queen, 80 DTC 6328, [1980] CTC 409 (FCTD)

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Sher v. The Queen, 80 DTC 6095, [1980] CTC 168 (FCTD)

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Chaffey v. MNR, 78 DTC 6167, [1978] CTC 293 (FCA)

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Frappier v. The Queen, 76 DTC 6066 (FCTD)

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The Queen v. Pollock Sokoloff Holdings Corp., 76 DTC 6181, [1976] CTC 349 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) loan must be made by taxpayer 122

MNR v. Kelvingrove Investments Ltd., 74 DTC 6357, [1974] CTC 450 (FCTD)

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The Queen v. Lavigueur, 73 DTC 5538, [1973] CTC 773 (FCTD)

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The Queen v. F.H. Jones Tobacco Sales Co. Ltd., 73 DTC 5577, [1973] CTC 784 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Substance 60

McLaws v. Minister of National Revenue, 72 DTC 6149, [1972] CTC 165, [1974] S.C.R. 887

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) guarantee obligation not borrowed money 117

Stewart & Morrison Ltd. v. Minister of National Revenue, 72 DTC 6049, [1972] CTC 73, [1974] S.C.R. 477

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Minister of National Revenue v. Freud, 68 DTC 5279, [1968] CTC 438, [1969] S.C.R. 75

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Terminal Dock and Warehouse Co. Ltd. v. MNR, 68 DTC 5060 (Ex Ct), aff'd 68 DTC 5316 (SCC)

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Minister of National Revenue v. Steer, 66 DTC 5481, [1966] CTC 731, [1967] S.C.R. 34

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Frontenac Shoe Ltée v. MNR, 63 DTC 1129 (Ex Ct)

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See Also

MacDonald v. The Queen, 2017 TCC 157, rev'd 2018 FCA 128

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges “the law still requires a close linkage between the purported hedging instrument and the underlying asset” 479

Turner v. The Queen, 2016 TCC 77 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base interest added to ACB 144

SRI Homes Inc. v. The Queen, 2014 DTC 1185 [at 3693], 2014 TCC 180

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Tax Topics - General Concepts - Fair Market Value - Other full repayment of shareholder loan, subsequent to its sale for less than book value, was not anticipated 123

Prochuk v. The Queen, 2014 DTC 1050 [at 2917], 2014 TCC 17

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business trading RRSP funds does not make the annuitant a trader 114
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares trading RRSP funds does not make the annuitant a trader 114

Mittal v. The Queen, 2013 DTC 1020 [at 106], 2012 TCC 417

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Zsebok v. The Queen, 2012 DTC 1127 [at 3145], 2012 TCC 99

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Swain v. The Queen, 2012 DTC 1086 [at 2921], 2012 TCC 46

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Chronis v. The Queen, 2010 DTC 1188 [at 3441], 2010 TCC 218

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Hayter v. The Queen, 2010 DTC 1176 [at 3395], 2010 TCC 255

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Krauss v. The Queen, 2009 DTC 1394 [at 2155], 2009 TCC 597

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Shaw-Almex Industries Limited v. The Queen, 2009 DTC 1377 [at 2080], 2009 TCC 538

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Words and Phrases
transaction

Valiant Cleaning Technology Inc. v. The Queen, 2008 DTC 5112, 2008 TCC 637

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Saskatchewan Wheat Pool v. The Queen, 2008 DTC 2520, 2008 TCC 8

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Howard v. The Queen, 2008 DTC 2788, 2008 TCC 51

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Laramee v. The Queen, 2007 DTC 1723, 2007 TCC 635

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Greenberg v. The Queen, 2007 DTC 124, 2006 TCC 608

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Hawa v. The Queen, 2007 DTC 28, 2006 TCC 612 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Onus 101

Corvalan v. The Queen, 2006 DTC 2907, 2006 TCC 200

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Excell Duct Cleaning Inc. v. The Queen, 2006 DTC 2040, 2005 TCC 776

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Cathelle Inc. v. The Queen, 2005 DTC 858, 2005 TCC 360

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Rajchgot v. The Queen, 2004 DTC 3090, 2004 TCC 548, aff'd 2005 DTC 5607, 2005 FCA 289

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Walchuk v. The Queen, 2003 DTC 2184, 2004 TCC 42

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Smith v. The Queen, 2003 DTC 215 (TCC)

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Grant v. The Queen, 2000 DTC 1985 (TCC) (Informal Procedure)

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Williams Gold Refining Co. of Canada v. The Queen, 2000 DTC 1829 (TCC)

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Magicuts Inc. v. The Queen, 98 DTC 2085 (TCC)

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Hamilton v. The Queen, 97 DTC 787 (TCC)

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Robertson v. The Queen, 97 DTC 449 (TCC)

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Campbell v. The Queen, 96 DTC 1221 (TCC)

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Fickes v. The Queen, 94 DTC 1969 (TCC)

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Faucher v. The Queen, 94 DTC 1581 (TCC)

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E.C.E. Group Ltd. v. MNR, 92 DTC 2019 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) disposition before year end 110

Lawson v. Johnson Matthey plc, [1992] BTC 324 (HL)

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Hill v. MNR, 91 DTC 1094 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 169 99

K.J. Beamish Construction Co. Ltd. v. MNR, 90 DTC 1584 (TCC)

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Tax Topics - General Concepts - Corporate/Separate Personality shareholder has no interest in corporation's assets 162
Tax Topics - General Concepts - Personality 115

Anglemont Estates Ltd. v. MNR, 88 DTC 1770 (TCC)

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Gestion Louis Riel Inc. v. MNR, 85 DTC 550 (TCC)

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Guinea Airways Ltd. v. Federal Commissioner of Taxation (1949), 83 C.L.R. 584 (HC of A.)

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Administrative Policy

25 September 2012 Internal T.I. 2011-0409281I7 F - Papier commercial - Obligations XXXXXXXXXX

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Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base acquiring client securities at the clients' cost rather than their lower FMV was reflected in portfolio manager's cost 156

29 July 2004 Internal T.I. 2003-002376

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18 June 1993 T.I. (Tax Window, No. 32, p. 3, ¶2593)

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31 July 1992 External T.I. 5-911918 -

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Articles

Dunbar, "Sale of Stock Plan Shares May Produce Fully-Deductible Loss", Taxation of Executive Compensation and Retirement, October 1991, p. 499.

Damages

Cases

McNeill v. The Queen, 2000 DTC 6211 (FCA)

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Hedges

Cases

The Queen v. MacDonald, 2018 FCA 128

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges cash-settled forward hedged bloc of shares irrespective of speculative intention 539