Words and Phrases - "hedge"

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MacDonald v. Canada, 2020 SCC 6

cash-settled forward sales were a hedge of a shareholding notwithstanding their settlement without a corresponding share sale and a stated intention to speculate
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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 319
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

cash-settled forward hedged bloc of shares irrespective of speculative intention
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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

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

“the law still requires a close linkage between the purported hedging instrument and the underlying asset”
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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

Echo Bay Mines Ltd. v. The Queen, 92 DTC 6437 (FCTD)

exact matching not required for hedging
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Words and Phrases
hedge