debt

Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(4) - Paragraph 181.2(4)(b)
balance of sale, although a debt, is not a “loan or advance”/ prepaid expenses are “advances”

The Agency indicated that “a balance of sale is a debt that does not have the character of a loan or advance within the meaning of paragraph...

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Words and Phrases
advance debt

Canadian Imperial Bank of Commerce v. The King, 2024 TCC 160 -- summary under Subparagraph 1(a)(ii)

Full Title
Canadian Imperial Bank of Commerce v. The King, 2024 TCC 160
Summary Under
Tax Topics - Excise Tax Act - Schedules - Schedule VI - Part IX - Section 1 - Paragraph 1(a) - Subparagraph 1(a)(ii)
CIBC’s interchange fees from a non-resident credit-card processor were not zero-rated as relating to the loans effectively made to its Cdn. cardholders

In 2001 (before the three annual fiscal periods in issue) the appellant (CIBC) outsourced part of its Visa-card transaction processing and payment...

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Words and Phrases
relates to
lending
debt
primarily
Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Property
“deferred salary” right of farmer descendant was a debt

Before finding that receipt of “deferred salary,” pursuant to a right established by French legislation, as compensation for contribution to...

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Words and Phrases
debt
Summary Under
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1)
good argument that an advance to be repaid out of the final pay was advance wages rather than a loan

The pay system would be changed so that the employees, who currently are paid at the end of each two-week period of work, would instead be paid...

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Words and Phrases
debt

Canada (Attorney General) v 18335898 Alberta Ltd (Whitecap Energy Inc), 2023 ABKB 357 -- summary under Subsection 209(6)

Full Title
Canada (Attorney General) v 18335898 Alberta Ltd (Whitecap Energy Inc), 2023 ABKB 357
Summary Under
Tax Topics - Other Legislation/Constitution - Federal - Canada Business Corporations Act - Section 209 - Subsection 209(6)
A.G. was an “interested party” who could apply to revive a dissolved corporation so as to convert its tax liability into a debt

The defendant (“Whitecap Energy”) was an Alberta corporation which had been wound up into its sole shareholder (“Whitecap Resources”) and...

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Words and Phrases
liable for tax
debt

Barejo Holdings ULC v. Canada, 2020 FCA 47 -- summary under Paragraph 94.1(1)(a)

Full Title
Barejo Holdings ULC v. Canada, 2020 FCA 47
Summary Under
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) - Paragraph 94.1(1)(a)
the amount payable under a “debt” for s. 94.1(1)(a) purposes need not be crystallized until maturity

An offshore fund ("SLT"), in which the taxpayer had an interest, invested in instruments (labelled as "Notes") of non-resident subsidiaries of...

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Words and Phrases
debt
liability

Moose Factory Restaurant Properties Ltd. v. The Queen, 2019 TCC 156 -- summary under Investment Contract

Full Title
Moose Factory Restaurant Properties Ltd. v. The Queen, 2019 TCC 156
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract
debt is obligation to pay a sum certain or amount reducible to sum certain

After quoting (at para.55) the statement in Sattva that “While the surrounding circumstances are relied upon in the interpretive process, courts...

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Words and Phrases
debt

Hokhold v. Canada, 2018 FCA 163 -- summary under Subparagraph 20(1)(p)(i)

Full Title
Hokhold v. Canada, 2018 FCA 163
Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i)
bad debt claim requires the specific identification of which “debt” claims went bad

Partly as a delayed consequence of CRA’s seizure of computers and dental equipment of a dental practice and the misplacing of records when his...

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Words and Phrases
debt

Colin Campbell, "Liability for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709: -- summary under Tax debt

Colin Campbell, "Liability for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709:
Summary Under
Tax Topics - Income Tax Act - Section 222 - Subsection 222(1) - Tax debt

"Liability" v. "debt" (pp. 716-717)

The distinction so clearly made by Jackett P in Terra Nova Properties [67 DTC 5064] between liability for tax...

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Words and Phrases
liability
debt
Summary Under
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) - Subparagraph 88(1)(d)(i)
future income tax liabilities not treated as obligations to pay an amount

Is the balance of the “future income tax liabilities” (being an accounting provision which was not deducted in computing income) presented in...

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Words and Phrases
debt

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