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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).