Principal Issues: 1) Whether the designation under paragraph 111(4)(e) could be made with respect to internally generated goodwill? 2) Whether a capital loss would be realized with respect to a loan receivable from a controlled foreign affiliate? 3) Whether the designation under paragraph 111(4)(e) could be made with respect to class 12 property?
Position: 1), 2) and 3): Yes.
Reasons: According the law and previous positions.