Précis: This is an appeal from a Tax Court decision blogged earlier on this site. Because of its exposure to currency risk in multiple jurisdictions Kruger Incorporated (“Kruger”) started an aggressive risk management program using foreign exchange options. The program expanded to the point that they had a foreign exchange desk in house similar to that found in mainstream investment houses. Kruger started to mark its foreign exchange contracts to market, in the same manner as financial institutions. CRA denied Kruger’s mark to market positions and Kruger appealed to the Tax Court.
Kruger v. R. - FCA: Kruger entitled to mark to market currency options issued by the corporationREAD MORE »