Words and Phrases - "novation"
21 July 2009 Internal T.I. 2009-0322591I7 F - Déduction des intérêts
The taxpayer purchased assets from the vendor (apparently, a non-resident) in consideration for shares of the taxpayer and interest-bearing debt,...
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|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | replacement of note with capitalized note with note for full amount did not constitute payment by novation | 119 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) | issuance of replacement promissory note for amount of previous principal plus capitalized interest was not a crediting of such interest | 151 |
13 July 2018 Internal T.I. 2017-0713301I7 - Assumption of accrued interest
The Partnership, a general partnership governed by the laws of a U.S. state that was a Canadian partnership under s. 102 as its partners were...
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.1) - Paragraph 212(13.1)(a) | withholding when debt of Canadian partnership assumed by sub | 171 |
Blank v Commissioner of Taxation, [2016] HCA 42
The taxpayer was employed by Glencore International AG (“GI”), an international commodity trading business incorporated in Switzerland, or a...
General Electric Capital Equipment Finance Inc. v. Canada, 2002 DTC 6734, 2001 FCA 392
Following assessments of withholding tax on interest on notes owing by the taxpayer, the notes were amended to decrease the principal owing (by...
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | material changes produced new obligation | 187 |
National Trust Co. v. Mead, [1990] 5 WWR 455, [1990] 2 S.C.R. 410
The execution by an individual ("Mead") of an assumption of liability agreement in favour of a mortgage lender ("National Trust"), with Mead...
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | tests for novation | 151 |
Carma Developers Ltd. v. The Queen, 96 DTC 1798, [1996] 3 CTC 2029 (TCC), briefly aff'd 96 DTC 6569 (FCA)
Under a plan that was approved by the requisite majority of creditors in accordance with the companies' Creditors Arrangement Act, various classes...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | 157 |