Words and Phrases - "hedge"

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88
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MacDonald v. Canada, 2020 SCC 6, [2020] 1 S.C.R. 319

Summary Under
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges
cash-settled forward sales were a hedge of a shareholding notwithstanding their settlement without a corresponding share sale and a stated intention to speculate

The taxpayer had held a significant investment in the common shares of a listed bank (“BNS”) since 1988. In 1997, due to “storm clouds,”...

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Words and Phrases
hedge speculation
Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention intention re forward contract determined on basis of objective linkage to hedged asset rather than testimony as to subjective purpose 335
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss - Hedges cash-settled forward “objectively” was a capital share hedge notwithstanding no matching share sale 542

The Queen v. Macdonald, 2018 FCA 128, aff'd 2020 SCC 6

Summary Under
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges
cash-settled forward hedged bloc of shares irrespective of speculative intention

The taxpayer had held a significant investment in the common shares of Bank of Nova Scotia (“BNS”) since 1988. In 1997, due to “storm...

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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 297

MacDonald v. The Queen, 2017 TCC 157, rev'd 2018 FCA 128, which was aff'd in turn by 2020 SCC 6

Summary Under
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges
“the law still requires a close linkage between the purported hedging instrument and the underlying asset”

The taxpayer had held a significant investment in the common shares of Bank of Nova Scotia (“BNS”) since 1988. In 1997, due to “storm...

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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 199

Echo Bay Mines Ltd. v. The Queen, 92 DTC 6437, [1992] 2 CTC 182 (FCTD)

Summary Under
Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1)
exact matching not required for hedging

MacKay J. found that the taxpayer (which operated a silver mine in the Northwest Territories) entered into forward sales contracts as hedging...

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Words and Phrases
hedge