Federal Court of Appeal Rules Paper Losses Cannot Offset Realized Capital Gains: 2763478 Canada Inc. v. Canada (2018 FCA 209)
FACTS Jobin owned shares in Groupe AST (assume FMV = $13 million and ACB = $nil). He received an offer for his shares from a third-party purchaser. To minimize his taxes, Jobin undertook the following steps. Jobin rolled his shares in Groupe AST – which had a fair market value of $13 million – on […]