Words and Phrases - "hedging"
Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 DTC 6532, 2006 SCC 20,  1 S.C.R. 715
Summary UnderTax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges
“hedging “ includes cash settled derivatives including options
The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phraseshedging
|Locations of other summaries||Wordcount|
|Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc.||shifting CRA position could not be relied upon except to evidence ambiguity||73|
|Tax Topics - Statutory Interpretation - Redundancy/reading in words||presumption against tautology||114|
|Tax Topics - Statutory Interpretation - Resolving Ambiguity||residual presumption in favour of the taxpayer||125|
|Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) - Paragraph 1204(1)(b)||cash-settled derivatives had the effect of fixing mine production]||399|
|Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation||addition of regulation did not significantly expand scope of tax||223|