Imperial Oil Ltd. v. Canada, 2004 DTC 6702, 2004 FCA 361, rev'd 2006 SCC 46 -- summary under Financing Expenditures

By services, 28 November, 2015

Before going on to find that foreign exchange losses realized by the taxpayer on repaying its debentures were capital losses under subsection 39(2) LeBel J. stated (at para. 32):

"Similarly, any foreign exchange loss on the debentures would be a payment on account of capital because the characterization of a foreign exchange gain or loss generally follows the characterization of the underlying transaction ... ."

Note
rev'd on other grounds 2006 SCC 46
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Topic
Income Tax Act - s. 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures
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