Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27

Summary Under

S. 20(1)(f) deduction unavailable where debt assumed (unless s. 248(26) available) (p. 18:12)

[P]aragraph 20(1)(f ) permits a deduction only to...

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Summary Under

Apply s. 52(1) basis increase to avoid double-taxation of s. 20(14)(a) income inclusion (p. 18:14)

If an amount is included in computing a...

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Summary Under

No s. 18(9.1) deduction for penalty incurred on disposition of property (p. 18:16)

[T]he CRA’s general view is that a penalty that is incurred...

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Summary Under

Whether specific tracing or blended aggregate approach should be applied in determining s. 39(2) gain or loss on FX debt partial repayments (p....

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Summary Under

Textual interpretation suggests that the “amount” of debt for s. 219.1 purposes is its FMV (p. 18:20)

Pursuant to subsection 219.1(1), a...

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