16 Matching Annotations
  1. Jul 2019
    1. All of the above works to distinguish the facts of the present matter from Capancini and Morasse where, in each case, the Court found that the shares received by the taxpayer had never been owned by the distributing parent company and did not, therefore, come within the meaning of “dividend in kind”. Here, the documentary evidence does nothing to refute the Minister’s assumption that Tyco International did own the Tyco Electronics and Covidien shares it ultimately distributed, thus putting the Appellant’s case on the same factual footing as Hamley and bringing it within Justice Hershfield’s analysis set out above at paragraph 7 of these Reasons. In these circumstances, there is no justification for the Court to interfere with the Minister’s reassessment.
    2. While it is not clear exactly how the facts were presented in Capancini, I believe that the Tyco transactions are distinguishable from the circumstances in Morasse.
    1. (c) in any other case, the amount of any stock dividend is the amount by which the paid-up capital of the corporation that paid the dividend is increased by reason of the payment of the dividend; (montant)

      Note that this definition is important for the purposes of ITA 52(3)(a)(i), which says that the cost of a stock dividend, for an individual, is equal to the "amount" of the stock dividend.

    1. But do the America Movil securities represent underlying profits of Telmex? What does the $12,432 reflect? Was there a corresponding decline in the value of the Telmex shares which offset the "value" received by Ms. Morasse in the form of the America Movil shares? In an annual report that Telmex filed with US Securities and Exchange Commission on August 23, 2001,[4] the trading history of Telmex ADS for the months of February and March 2001 showed a decline from a high of $54 to approximately $34 a share. Recall that the spin-off took place in February 2001. Ms. Morasse held 400 Telmex ADRs and therefore suffered a drop in the value at that time of approximately US$8,000. Presuming an exchange rate of approximately one and one-half to one, this amounts to roughly $12,000 or just shy of the value the Respondent has attributed as income of Ms. Morasse on receipt of the America Movil shares.

      In answering the question of whether there was income, the Court asks whether there was a corresponding decline in the value of the Telmex shares and concludes that there was -- in almost exact proportion to the value of the shares issued.

      Note, however, that this conclusion was specifically rejected in Rezayat v. The Queen, 2011 TCC 286 (CanLII), http://canlii.ca/t/flrrl, retrieved on 2019-07-05.

  2. May 2019
  3. Mar 2019
    1. Given that a lot is happening in Q1, we do not expect to be profitable in the first quarter

      Probably the stocks will drop a lot when announced, buy after that. Should recover in next quarter.

  4. Feb 2019
    1. But I actually think stock and flow is a useful metaphor for media in the 21st century. Here’s what I mean: Flow is the feed. It’s the posts and the tweets. It’s the stream of daily and sub-daily updates that reminds people you exist. Stock is the durable stuff. It’s the content you produce that’s as interesting in two months (or two years) as it is today. It’s what people discover via search. It’s what spreads slowly but surely, building fans over time.
    1. Reorder sales are strong: on a TTM basis, they've risen 21% in just the past two years. But the obvious top-line concern here is that smaller new customer cohorts will pressure reorder sales at some point down the line. And with Chewy Pharmacy launching this summer, competitive pressure for new customers is only going to get more intense going forward.

      How will Chewy Pharmacy be structured compared to PETS's business model?

    2. Reorder sales (which includes any customer who has previously placed an order) rose 10%+. New order sales, however, fell by about the same amount.

      What would the re-order sales of PetMed Express vs. new order sales be in the future?

    3. It operates a "gray market" business model, in which it acquires inventory indirectly, angering veterinarians and suppliers in the process.

      Where exactly does PETS source its inventory?

    4. largely irregular purchases

      What is the cycle for sales typically?

  5. Jan 2019
    1. DX Exchange uses Nasdaq’s Financial Information Exchange (FIX) protocol to facilitate trades. Using this platform, DX Exchange allows users to swap tokenized stocks in major global companies, including Amazon, Baidu, Apple, Facebook, Google, Intel, Microsoft, Netflix, Nvidia, and Tesla. All of these companies will be available for trading on the platform as easily as you would swap tokens on a conventional cryptocurrency exchange.

      <big>评:</big><br/><br/>

      DX.Exchange 此举中,值得讨论的一点在于,「每一种数字代币都有一股普通股作为支撑,持有者将有权获得相同的现金股息,尽管这些公司本身并未参与其中」。 </br></br> 这让人联想到这些年来社交网络上有关「被代表」的讨论。时不时有声音呼吁民众对巨型官僚机构和商业公司保持警惕,但是当「代表」与「被代表」的两方角色互换,反转后的清奇画面又让人惊愕。这样一来,那些发声者又该如何回应?也许他们可以说,这不过是巨型商业公司的自导自演而已。

  6. Nov 2018
    1. So where does the remaining $2 billion a year go? Into expansion? No, ten years of the savings will help pay for the $20 billion stock buyback announced last fall.
    2. companies have claimed that the sudden influx of money, which will likely go to boosting stock prices (top executives and board members are shareholders, too), actually allows them to invest in employees and their businesses. But they generally follow a pattern of doing something seemingly flashy for employees that lasts a year or less following by something far more obviously moderate over time
  7. Sep 2018
  8. Oct 2015