2017 Ruling 2017-0693751R3 - Transfer of Shares of a Foreign Affiliate -- attach -- Shares
affiliated transfer of shares at gain equal to exempt surplus did not cause loss of capital property status
Shares
2016 Ruling 2016-0648991R3 - Internal spinoff reorganization of XXXXXXXXXX -- attach -- Shares
shares did not lose capital property character on internal spin-off transfer with a view to their further dorp-down
Resource Capital Fund IV LP v Commissioner of Taxation, [2018] FCA 41 (Federal Court of Australia), rev'd on various grounds [2019] FCAFC 51 -- attach -- Shares
private equity fund LP with 5-year holding objective realized share gain on income account
Foote v. The Queen, 2017 TCC 61 -- attach -- Shares
senior stock broker realized gains on a small personal portfolio on income account
Shares - Commentary
Shares as investments
Canada v. Lysanne Gendron, 2016 FCA 1 -- attach -- Shares
preordained resale of shares at no commercial profit was not an adventure
86 C.R. - Q.16 -- attach -- Shares
Irrigation Industries Ltd. v. The Minister of National Revenue, 62 DTC 1131, [1962] CTC 215, [1962] S.C.R. 346 -- attach -- Shares
shares generally an investment/ isolated transaction in junior resource company was on capital account
Minister of National Revenue v. Foreign Power Securities Corporation Ltd., 67 DTC 5084, [1967] CTC 116, [1967] S.C.R. 295 -- attach -- Shares
shares of 2 utility companies were acquired, at cost from the parent, as an investment
Adamson, "Portfolio Securities Transactions", 1992 Canadian Tax Journal, No. 3, p. 736. -- attach -- Shares
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