Words and Phrases - "speculation"
MacDonald v. Canada, 2020 SCC 6
Summary Under
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedgescash-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,”...
Locations of other summaries | Wordcount | |
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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 |