directly or indirectly

By services, 25 November, 2018

Louie v. The Queen, 2018 TCC 225, rev'd in part on "advantage" issue (for subsequent years) 2019 FCA 255 -- summary under Subparagraph (b)(i)

From May 15 to October 17, 2009, the taxpayer directed 71 “swaps” under which TSX-listed shares were transferred between her self-directed tax-free savings account (“TFSA”) and her taxable trading account (“CDN”) at TD Waterhouse Discount Brokerage (“TDW”), or between her TFSA and her self-directed registered retirement savings plan (also with TDW). The TDW policy was to permit a transfer to occur at any price between the high and low trading prices for the day.

By services, 17 February, 2018

Resource Capital Fund IV LP v Commissioner of Taxation, [2018] FCA 41 (Federal Court of Australia), rev'd on various grounds [2019] FCAFC 51 -- summary under Subparagraph 115(1)(a)(ii)

Two Caymans investment LPs (“RCF IV” and RCF V”) whose limited partners were mostly U.S. residents, realized gains from the disposal of shares of significant shareholdings in a TSX-listed Australian corporation (Talison Lithium) which, through a grandchild corporation, held mining leases in Australia and carried out an operation there of mining lithium ores and processing them.

directly or indirectly