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Commentary

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Cases

Imperial Stables (1981) Ltd. v. The Queen, 90 DTC 6135 (FCTD), aff'd 92 DTC 6189 (FCA)

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Cook v. The Queen, 87 DTC 5231, [1987] 1 CTC 377 (FCTD)

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Hillsdale Shopping Centre Ltd. v. The Queen, 81 DTC 5261, [1981] CTC 322 (FCA)

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Thom v. The Queen, 79 DTC 5324, [1979] CTC 403 (FCTD)

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Westcon Engineering and Contractors Ltd. v. The Queen, 77 DTC 5398, [1977] CTC 567 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Commodities, and commodities futures and derivatives exercise of aircraft purchase option and immediate resale 103

See Also

Rogers Estate v. The Queen, 2015 DTC 1029 [at 124], 2014 TCC 348

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) cash surrender of employee stock options for their value was not shareholder benefit 116
Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) capital gain can arise from property which is not capital property 249
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) exercise of stock option surrender plan for FMV was not "remuneration" 111
Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(a) s. 7 a complete code for taxation of stock option benefits 214

Street v. MNR, 91 DTC 369 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Computation of Profit income inclusion added to cost on general principles 41

Administrative Policy

30 May 2005 External T.I. 2005-0127861E5 - Securities transactions - capital gain or income

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28 May 2003 External T.I. 2003-0011605 - OEX INDEX OPTIONS

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19 October 1999 External T.I. 9925055 - GAINS & LOSSES ON OPTIONS

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May 1995 Executive Institute Round Table, Q. 24 (C.T.O. "Employee Stock Option")

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IT-479R "Transactions in Securities"

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Articles

Ian Gamble, "Income from a Business or Property: General Principles and Current Issues", 2014 Conference Report, Canadian Tax Foundation, 5:1-32

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