10 July 1991 Decision Summary (Tax Window, No. 5, p. 12, ¶1346)

S.80 will not apply to debt restructurings involving an extension of the time to repay or a change in the method of calculating interest at a commercial rate, provided there is no novation. However, s. 80 should apply on the conversion of an interest-bearing debt to a non-interest bearing debt because such a conversion does not indicate a genuine restructuring.

S.80 will not apply to debt restructurings involving an extension of the time to repay or a change in the method of calculating interest at a commercial rate, provided there is no novation. However, s. 80 should apply on the conversion of an interest-bearing debt to a non-interest bearing debt because such a conversion does not indicate a genuine restructuring.