In Rudolph v R, 2024 TCC 148, the Court determined that gains and losses realized by the taxpayer on the sale of shares and the expiry of related options were on income account. The Court noted, among other things, that the taxpayer had intended to sell the shares for a profit as soon as possible, that he had borrowed money to purchase some shares and that he had played an active role in the business of the issuer of the shares.
Summarized in Tax Topics 2723 (January 28, 2025)
