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We continue our Synthetic Dispositions series this week with a look at an example of a Put-Call Collar and the effect of the March 21, 2013 federal budget has on reporting requirements.
Daishowa-Marubeni International Ltd v. Her Majesty The Queen [2013] SCC 29 An important and eliciting tax decision was recently released by the Supreme Court of Canada (SCC) analyzing the difference between liabilities and embedded obligations as well as the role of tax symmetry in the Income Tax Act (the Act).
Up until 2009, CRA took the position that where you accumulate frequent flyer points while travelling on employer-paid business trips and used them to obtain air travel or other benefits for personal use by you or your family, the fair market value of such air travel or other benefits must be included in your income.
The March 21, 2013 budget closed several loopholes including synthetic dispositions. Knowledge Bureau Report has been examining examples of arrangements that are now closed and their financial outcomes. Last issue we examined the forward sale of securities; in this issue, we provide an example involving the forward sale of other assets.