Précis: The only issue in this appeal was whether a profit of roughly $57,000,000 that Barrick earned in closing out gold forward contracts formed part of its gross resource profits. The Minister denied that treatment and Barrick appealed to the Tax Court. The Tax Court in a nutshell held that the profits on the forward contracts “were an integral part of the Appellant’s business of producing and processing gold ore and therefore that the profit that arose from closing out the Contracts were sufficiently connected to those activities to constitute income from that source and therefore are properly part of its gross resource profits in 1998. [para. [40]” As a result the appeal was allowed with costs.
Barrick Gold v. R. - TCC: Profits on gold hedges formed part of gross resource profitsREAD MORE »