Futures/Forwards/Hedges

Commentary

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Cases

The Queen v. Macdonald, 2018 FCA 128

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Words and Phrases
hedge
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss - Hedges cash-settled forward was hedge of share bloc irrespective of speculative intention 269

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 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss silver futures trading on income account 114

Atlantic Sugar Refineries v. Minister of National Revenue, 49 DTC 602, [1949] S.C.R. 706

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See Also

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

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Words and Phrases
hedge
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss cash-settled forward sale of shares not sufficiently linked to underlying shareholding to be a hedge 193

Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 DTC 6532, 2006 SCC 20, [2006] 1 S.C.R. 715

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Words and Phrases
hedging
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. shifting CRA position could not be relied upon except to evidence ambiguity 73
Tax Topics - Statutory Interpretation - Redundancy/reading in words presumption against tautology 114
Tax Topics - Statutory Interpretation - Resolving Ambiguity residual presumption in favour of the taxpayer 125
Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) - Paragraph 1204(1)(b) cash-settled derivatives had the effect of fixing mine production] 399
Tax Topics - Statutory Interpretation - Regulations addition of regulation did not significantly expand scope of tax 223

Friesen v. The Queen, 95 DTC 492 (TCC)

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Administrative Policy

6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 16, 2017-0705181C6 F - Hedging & George Weston Limited

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21 October 2015 Internal T.I. 2015-0592781I7 - treatment of bond locks

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Timing losses on interest or dividend rate hedges could be amortized/any gains immediately includible 213

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 - Foreign Exchange s. 85(1) roll of FX forward to sub 183

8 October 2010 CTF Roundtable, 2013-0507191C6 - Monetization of Securities - 2010 CTF Conference

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(b) payment under an equity swap not a capital loss because no disposition (and on income account) 177

2007 Ruling 2007-0246461R3 F - Monétisation d'actions d'une société publique

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12 January 2005 Miscellaneous 2004-0101161E5 - Trading in stock index futures

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4 August 1994 External T.I. 9414045 - FINANCIAL FUTURES - CAPITAL OR INCOME ACCOUNT

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25 May 1994 External T.I. 5-940421 -

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31 March 1994 T.I. 933701 (C.T.O. "Mutual Fund Trust Investing in Futures - Income Account")

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Articles

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

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Raj Juneja, "Taxation of equity derivatives", 2015 CTF Annual Conference paper

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