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Response : A defensible and workable approach to the income tax treatment of financial instruments

Edgar, Tim 2002, Response : A defensible and workable approach to the income tax treatment of financial instruments, Canadian tax journal, vol. 50, no. 1, pp. 249-260.

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Title Response : A defensible and workable approach to the income tax treatment of financial instruments
Author(s) Edgar, Tim
Journal name Canadian tax journal
Volume number 50
Issue number 1
Start page 249
End page 260
Publisher Canadian Tax Foundation
Place of publication Canada
Publication date 2002
ISSN 0008-5111
Keyword(s) financial instruments
hedging
equity financing
derivatives
debt financing
financing
Summary It is a privilege to have the opportunity to respond to the comments on my monograph1 provided by Mark Gergen, Glenn May, and Gordon Longhouse. Their comments, which are inevitably coloured by their very different perspectives, reflect the considerable expertise that each one of them has in the area of the income taxation of financial instruments. Indeed, it is with some hesitation that I offer a response in defence of various portions of the analysis presented in my monograph in support of some pretty modest proposals in this extremely difficult area of income tax law. Although I spent considerable time exploring some necessary first principles and their implications for the design of a system for the income taxation of financial instruments, I made several concessions to certain practical constraints that led me to support, in some measure, the status quo reflected in certain of the existing literature, as well as the legislation in a select group of countries. On the assumption that many readers may be unfamiliar with the monograph, I propose to respond by outlining much of my analysis in the monograph and the proposals that are the logical outcome. Throughout the outline, I will highlight and respond to what I see as the important points of difference emphasized by Gergen, May, and Longhouse.
Language eng
Field of Research 180125 Taxation Law
HERDC Research category C1 Refereed article in a scholarly journal
Persistent URL http://hdl.handle.net/10536/DRO/DU:30001815

Document type: Journal Article
Collection: Law
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