Words and Phrases - "hedging"
Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 DTC 6532, 2006 SCC 20, [2006] 1 S.C.R. 715
Summary Under
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges“hedging “ includes cash settled derivatives including options
The taxpayer sold its gold production to bullion dealers at the spot price but also, in order to manage the risk associated with fluctuations in...
Words and Phrases
hedgingLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | shifting CRA position could not be relied upon except to evidence ambiguity | 79 |
Tax Topics - Statutory Interpretation - Redundancy/reading in words | presumption against tautology | 120 |
Tax Topics - Statutory Interpretation - Resolving Ambiguity | residual presumption in favour of the taxpayer | 133 |
Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) - Paragraph 1204(1)(b) | cash-settled derivatives had the effect of fixing mine production] | 453 |
Tax Topics - Statutory Interpretation - Regulations/Statutory Delegation | addition of regulation did not significantly expand scope of tax | 264 |