Tip Top Tailors Limited v. The Minister of National Revenue, 57 DTC 1232, [1957] CTC 309, [1957] S.C.R. 703 -- attach -- Foreign Exchange
FX gain from settlement of foreign currency overdraft incurred in trading operations was on income account
Foreign Exchange
21 December 2012 Internal T.I. 2012-0465561I7 - Hedging transaction -- attach -- Foreign Exchange
hedge of CFA's debt on income account
16 December 1991 Memorandum 903636 [general principles] -- attach -- Foreign Exchange
general principles
Shell Canada Ltd. v. Canada, 99 DTC 5669, [1999] 3 SCR 622, [1999] 4 CTC 313 -- attach -- Foreign Exchange
FX hedging gain was capital gain as hedged borrowing was on capital account
George Weston Limited v. The Queen, 2015 TCC 42 -- attach -- Foreign Exchange
cross-currency swap was a hedge notwithstanding no intention to sell underlying indirect U.S. asset
2004 Ruling 2004-008527 -- attach -- Foreign Exchange
leased equipment financing on income account
Netupsky v. The Queen, 92 DTC 2282, [1992] 2 CTC 2531 (TCC) -- attach -- Foreign Exchange
loss on Swiss Franc borrowings to fund commodities' trading was on income account, notwithstanding that it was secured by a capital property
AVCO Financial Services Ltd. v. Federal Commissioner of Taxation, 82 ATC 4246, [1980] FCA 187 (HC) -- attach -- Foreign Exchange
International Nickel Australia Ltd. v. Commissioner of Taxation of the Commonwealth of Australia (1977), 137 C.L.R. 347 -- attach -- Foreign Exchange
Caltex v. Federal Commissioner of Taxation (1960), 12 A.T.D. 170 (HC) -- attach -- Foreign Exchange
novation with new supplier not a realization event
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