The taxpayer was the president and general manager of a Canadian company involved in the fabrication of
Question:
The taxpayer was the president and general manager of a Canadian company involved in the fabrication of various products of non-ferrous metals, including lead. The company purchased all of its lead requirements from a Canadian supplier which was the only producer of lead in Canada. However, the Canadian supplier held the company to a quota and, as a result, the company lost considerable business.
In these circumstances, the Canadian company requested the permission of its U.S. parent to import foreign lead. This meant buying it for future delivery in about three months. The risk of importing lead for future delivery was contrary to the business policy set for the Canadian company by the U.S. parent. However, the taxpayer was granted permission to purchase the lead himself and sell it to the Canadian company, assuming personally whatever risk was involved in the transaction.
The taxpayer made arrangements for the purchase of 1,500 tons of the foreign lead and for its sale to the Canadian company, on its arrival, at the market price of lead on the date of its arrival. He did not, himself, have to put up any money for the purchase of the lead. On the transaction, the taxpayer made a substantial profit.
REQUIRED
Determine whether the profit made by the taxpayer was a capital gain or income from business or property.
Step by Step Answer:
Introduction To Federal Income Taxation In Canada 2016-2017
ISBN: 9781554968725
37th Edition
Authors: Robert E. Beam, Stanley N. Laiken, James J. Barnett