Words and Phrases - "speculation"

a
85
b
44
c
75
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
54
n
25
o
38
p
79
q
3
r
76
s
88
t
46
u
15
v
9
w
22
y
2
“
1

MacDonald v. Canada, 2020 SCC 6

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