Mark Coleman, Daniel A. Bellefontaine, "Forgiveness, Foreign Affiliates and FAPI: a Framework", Resource Sector Taxation (Federated Press), Vol. X, No. 1, 2015, p.694

Summary Under

Loans subject to s. 95(2)(a)(ii)(B) or (D) not commercial debt obligations (p. 695)

[I]f interest on a loan owing by a debtor affiliate to another...

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Summary Under

Application of forgiven amount only to reduce losses (p. 697)

[O]ne of the main distinctions between the FAPI debt forgiveness regime and the...

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Summary Under

Priority of s. 15(1.2) rule (pp. 698-9)

[T]he existence of this rule suggests that a forgiven shareholder loan will typically be considered a...

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Summary Under

Whether foreign tax on forgiven amount can be FAT (p. 699)

[T]he definition of FAT requires that the relevant foreign income tax reasonably be...

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