Cases
Tamas v. The Queen, 81 DTC 5150, [1981] CTC 220 (FCTD)
Losses sustained by the taxpayer radiologist from the purchase and sale of silver futures were fully deductible. Dubé J stated (at p....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | silver futures trading on income account | 114 |
Atlantic Sugar Refineries v. Minister of National Revenue, 49 DTC 602, [1949] S.C.R. 706
The taxpayer was in the business of purchasing, refining and selling sugar. It did not normally engage in hedging transactions. However, on the...
See Also
Friesen v. The Queen, 95 DTC 492 (TCC)
The taxpayer, who did not have any business enterprises relating to the commodities in question, traded 66 times in commodities contracts (both...
Administrative Policy
21 October 2015 Internal T.I. 2015-0592781I7 - treatment of bond locks
Canco, which was wholly-owned by its Canadian Parent, entered into “Dividend Bond Locks” and “Interest Bond Locks” (collectively, the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Timing | losses on interest or dividend rate hedges could be amortized/any gains immediately includible | 235 |
5 March 2014 Internal T.I. 2013-0500891I7 - Hedging
Parent hedged a U.S.-dollar borrowing by entering into foreign currency forward contracts. In order to utilize capital loss carryforwards of a...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) | s. 85(1) roll of FX forward to sub | 110 |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange | s. 85(1) roll of FX forward to sub | 195 |
8 October 2010 CTF Annual Conference Roundtable, 2013-0507191C6 - Monetization of Securities - 2010 CTF Conference
Respecting arrangments for the monetization of shares of public corportions, CRA stated:
Ruling F in document 2007-0246461R3 provides that the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(b) | payment under an equity swap not a capital loss because no disposition (and on income account) | 187 |
2007 Ruling 2007-0246461R3 F - Monétisation d'actions d'une société publique
Proposed transactions
Holdco A and Holdco X (which are holding companies of the CEO and executive vice-president, respectively, of ACO, which is a...
12 January 2005 External T.I. 2004-0101161E5
Would trading by an individual, who makes trades every day and where they constitute the major source of income, in stock index futures which are...
4 August 1994 External T.I. 9414045 - FINANCIAL FUTURES - CAPITAL OR INCOME ACCOUNT
Would trading in futures by a mutual fund give rise to capital gains, rather than ordinary income? CRA responded:
Although Interpretation Bulletin...
25 May 1994 External T.I. 5-940421
A seat owner-member of a Futures Exchange whose business activity consisted of trading in futures would be required to report his transactions on...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares | 28 |
31 March 1994 T.I. 933701 (C.T.O. "Mutual Fund Trust Investing in Futures - Income Account")
A mutual fund that invests primarily in derivatives, futures and like investments will realize resulting gains and losses on income account....
Articles
Raj Juneja, "Taxation of equity derivatives", draft 2015 CTF Annual Conference paper
Potential capital treatment of equity derivatives (p.15)
[E]quity derivatives in many cases are not entered into to hedge exposure to other...
Commentary
Where the business of a corporation entails the purchase or sale of a particular commodity (e.g., the sugar purchases of a sugar refiner), gains...