The Resource A marked disagreement : mark-to-market valuation allowed for foreign exchange option contracts, but not as inventory : Kruger Incorporated v. Canada : 2016 FCA 186

A marked disagreement : mark-to-market valuation allowed for foreign exchange option contracts, but not as inventory : Kruger Incorporated v. Canada : 2016 FCA 186

Label
A marked disagreement : mark-to-market valuation allowed for foreign exchange option contracts, but not as inventory : Kruger Incorporated v. Canada : 2016 FCA 186
Title
A marked disagreement : mark-to-market valuation allowed for foreign exchange option contracts, but not as inventory : Kruger Incorporated v. Canada : 2016 FCA 186
Creator
Subject
Language
eng
Summary
In Kruger, the Federal Court of Appeal overturned the decision of the Tax Court of Canada and held that the taxpayer, Kruger Incorporated could value foreign exchange option contracts on a mark-to-market basis in computing its losses in respect of the options under subsection 9(2) of the Income Tax Act. The Court also found that none of the options held by Kruger in the relevant taxation year were inventory to be valued in accordance with subsection 10(1) because options that were written by Kruger were not "property" for the purposes of the Act, and options that were purchased by Kruger fell within a category of property that was neither inventory not capital property (overturning the Tax Court's decision in respect of the purchased options). The decision on both points are of significant interest, particularly to taxpayers engaged in derivatives trading, and threaten to result in a great deal of uncertainty and future litigation
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 64 (2016), no. 4 ; p. 817-824
http://library.link/vocab/creatorName
Walker, R. (Ryan)
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • foreign exchange
  • derivative financial instrument
  • valuation
  • case law
Label
A marked disagreement : mark-to-market valuation allowed for foreign exchange option contracts, but not as inventory : Kruger Incorporated v. Canada : 2016 FCA 186
Instantiates
Publication
Label
A marked disagreement : mark-to-market valuation allowed for foreign exchange option contracts, but not as inventory : Kruger Incorporated v. Canada : 2016 FCA 186
Publication

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