indebtedness

Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(f)
characterization as “loans and advances” and “all other indebtedness” based on legal character

A factoring company advances sums to Corporation A at a discount to the face value of the discounted receivables, and then applies the amounts...

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Words and Phrases
loan advance indebtedness
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract
indemnity agreement was not "indebtedness"

Before finding that an indemnity agreement was not "indebtedness," CRA discussed authorities on "indebtedness" including Fingold, Beament and

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Words and Phrases
indebtedness

Barejo Holdings ULC v. The Queen, 2015 DTC 1216 [at at 1405], 2015 TCC 274, aff'd on other grounds 2016 FCA 304 -- summary under Investment Contract

Full Title
Barejo Holdings ULC v. The Queen, 2015 DTC 1216 [at at 1405], 2015 TCC 274, aff'd on other grounds 2016 FCA 304
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract
"notes" which tracked actively-managed reference pool of assets were "debt"

The question referred by the parties pursuant to Rule 58 was whether two contracts, entitled Notes and issued for US $998 million by affiliates of...

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Words and Phrases
debt
indebtedness
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