Foreign Exchange

Commentary

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Cases

Shell Canada Ltd. v. Canada, 99 DTC 5669, [1999] 3 S.C.R. 622

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Substance legal relationships prevail over economic realities 193
Tax Topics - General Concepts - Tax Avoidance taxpayes entitled to rely on structure of their transactions 152
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) borrowing in legal substance was in weak currency 170
Tax Topics - Income Tax Act - Section 67 90
Tax Topics - Statutory Interpretation - Specific v. General Provisions 90

Ethicon Sutures Ltd. v. The Queen, 85 DTC 5290, [1985] 2 CTC 6 (FCTD)

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Neonex International Ltd. v. The Queen, 78 DTC 6339, [1978] CTC 485 (FCA)

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Salada Foods Ltd. v. The Queen, 74 DTC 6171, [1974] CTC 201 (FCTD)

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Northern Sales (1963) Ltd. v. MNR, 73 DTC 5200, [1973] CTC 239 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 96 142

Alberta Gas Trunk Line Co. Ltd. v. Minister of National Revenue, [1972] S.C.R. 498, 71 DTC 5403, [1971] CTC 723

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Alberta Natural Gas Company v. Minister of National Revenue, 71 DTC 5400, [1971] CTC 718, [1972] S.C.R. 490

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D.W.S. Corp. v. MNR, 68 DTC 5045, [1968] CTC 65 (Ex Ct), briefly aff'd 69 DTC 5203 (SCC)

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Aluminium Union Ltd. v. MNR, 60 DTC 1138, [1960] CTC 260, briefly aff'd 63 DTC 1254

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Tip Top Tailors Limited v. The Minister of National Revenue, 57 DTC 1232, [1957] CTC 309, [1957] S.C.R. 703

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British Columbia Electric Railway Co. v. Farrer, 55 DTC 1139, [1955] CTC 198, [1955] S.C.R. 757

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See Also

Loblaw Financial Holdings Inc. v. The Queen, 2018 TCC 182

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 165 - Subsection 165(1.11) requirement met where Crown knew the nature and quantum of the dispute 259
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Foreign Bank CFA qualified as a foreign bank since it was licensed under Barbados law as an international bank 117
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Business - Paragraph (a) Barbados-licensed international bank, which used Loblaw funding to invest responsively to Loblaw considerations, conducted an offside non-arm’s length business 425
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Business - Paragraph (c) employee equivalents was reduced by employee time described in s. 95(2)(b) 284
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.01) - Paragraph 152(4.01)(a) - Subparagraph 152(4.01)(a)(ii) GAAR is generally a separate matter rather than being subsumed in the allegedly-misused substantive provision 194
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) application of GAAR required the occurrence of an avoidance transaction (or series) in non-statute-barred years and the relevant previous year’s avoidance transaction did not occur as part of the series 496
Tax Topics - Income Tax Act - Section 248 - Subsection 248(10) hiring of employees 15-years previously to engage foreign bank exception to investment business definition was not part of same series as renewal of foreign bank licence 216
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) use of Barbados sub to engage in proprietary trading for Canadian parent misused the foreign bank exemption, whose purpose was promoting international competitiveness 322
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(l) purpose of s. 95(2)(l) exception was to permit non-resident subsidiaries of Canadian banks and dealers to compete internationally 184

George Weston Limited v. The Queen, 2015 TCC 42

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence hedge financing not an area of common knowledge 93

Saskferco Products Inc. v. The Queen, 2007 DTC 1183, 2007 TCC 462, aff'd 2008 FCA 297

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CCLI (1994) Inc. v. The Queen, 2006 DTC 2695, 2006 TCC 240

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Imperial Oil Ltd. v. Canada; Inco Ltd. v. Canada, 2006 DTC 6639, 2006 SCC 46, [2006] 2 S.C.R. 447

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Federal Commissioner of Taxation v. Energy Resources of Australia Ltd., 94 ATC 4923, [1994] FCA 924 (Full Fed. Ct.)

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Netupsky v. The Queen, 92 DTC 2282 (TCC)

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Beauchamp v. F.W. Woolworth plc, [1989] BTC 233, [1989] UKHL TC_61_542 (HL)

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Overseas Containers (Finance) Ltd. v. Stoker, [1989] BTC 153 (C.A.)

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Pattison v. Marine Midland Ltd., [1983] BTC 448, [1984] 2 WLR 11 (HL)

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AVCO Financial Services Ltd. v. Federal Commissioner of Taxation, 82 ATC 4246, [1980] FCA 187 (HC)

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International Nickel Australia Ltd. v. Commissioner of Taxation of the Commonwealth of Australia (1977), 137 C.L.R. 347

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Commercial and General Acceptance Ltd. v. Commissioner of Taxation (1977), 51 A.L.J.R. 842 (HC)

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Caltex v. Federal Commissioner of Taxation (1960), 12 A.T.D. 170 (HC)

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Davies v. Shell Co. of China, Ltd. (1951), 32 TC 133 (CA)

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Administrative Policy

29 January 2015 Internal T.I. 2014-0544651I7 - Section 85 transfer of Swap Contracts

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Inventory swap contract treated as inventory 49
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) swap contract treated as inventory 166
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) swap contract recorded on securities rather than inventory line of T2057 237

28 May 2015 IFA Roundtable Q. 1, 2015-0577691C6 - IFA 2015, Q.1: George Weston decision

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5 March 2014 Internal T.I. 2013-0500891I7 - Hedging

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) s. 85(1) roll of FX forward to sub 104
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges s. 85(1) roll of FX forward to sub 183

26 June 2013 External T.I. 2013-0481691E5 - Hedging - ITA 39(2)

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21 December 2012 Internal T.I. 2012-0465561I7 - Hedging transaction

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12 October 2010 Internal T.I. 2010-0367611I7 - Cross Currency swap - Income or Capital

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30 October 2008 Internal T.I. 2008-0297081I7 - Foreign Exchange

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2004 Ruling 2004-008527 -

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16 December 1991 Memorandum 903636 [general principles]

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29 January 1999 Internal T.I. 7-990047 -

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30 August 1995 T.I. 952095 [borrowing for capital purpose on capital account]

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1995 Memorandum 942716 [general purpose borrowings on capital account unless under-capitalied]

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Revenue Canada Round Table TEI, 16 May 1994, Q. 11 (C.T.O. "Foreign Exchange Gains and Losses")

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10 March 1992 T.I. (Tax Window, No. 17, p. 21, ¶1798 )

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16 December 1991 Issue Sheet (Tax Window, No. 11, p. 21, ¶1540)

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19 April 1990 T.I. (September 1990 Access Letter, ¶1414)

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88 C.R. - "Finance and Leasing" - "Hedging Transactions"

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84 C.R. - Q. 60

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84 C.R. - Q.63

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base 26

IT-270R2 "Foreign Tax Credit" under "Amount Paid by the Taxpayer for the Year"

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) 13

Articles

Broadhurst, "Foreign Exchange Planning", 1993 Corporate Management Tax Conference Report, c. 8.

Stephen S. Ruby, "Recent Financing Techniques", 1989 Conference Report (CTF), C. 27 [cited in Shell, supra].

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