MacDonald v. R. – SCC: Supreme Court grants taxpayer leave to appeal in hedge transaction case – is intention an element of a hedge?

MacDonald v. R. – SCC:  Supreme Court grants taxpayer leave to appeal in hedge transaction case – is intention an element of a hedge?

https://www.scc-csc.ca/case-dossier/info/dock-regi-eng.aspx?cas=38320

James S.A. MacDonald v. Her Majesty the Queen (March 21, 2019 – SCC - Court File 38320).

Précis:   The Supreme Court of Canada granted the taxpayer leave to appeal a decision of the Federal Court of Appeal blogged on this site last year:

https://decisions.fca-caf.gc.ca/fca-caf/decisions/en/item/312121/index.do

The Federal Court of Appeal held that intention did not form part of hedge transactions for income tax purposes.  The Supreme Court will now revisit that finding.