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Carrie Smit, "Debt Restructuring and the Falling Canadian Dollar" -- summary under Paragraph 80(2)(k)

Example of separate s. 80(2)(k) forgiven amount and s. 39(2) FX gain (pp. 5-6) [A]ssume that the Canadian debtor described above is now settling and extinguishing the US$100 million debt for cash consideration of US$15 million (or CDN$21.43 million). ...

Didier Fréchette, Ryan Rabinovitch, "Current Issues Involving Foreign Exchange", 2015 CTF Annual Conference paper -- summary under Subsection 15(2.6)

As a result of the significant appreciation in the value of the US dollar…the repayment of the loan in cash by Forco would result in a capital gain in the hands of Canco under 39(1).... 1) Cansub assumes the loan as consideration for a cash payment by Forco equal to the amount outstanding under the loan. ...

Gregory M. Johnson, Wesley R. Novotny, "An Update on Flow-through Shares in the Energy Sector", 2016 Conference Report (Canadian Tax Foundation),12:1-39 -- summary under unattached

These fees could be viewed as a return of consideration paid by the PBC to the UWs and could fall within regulation 6202.1(1)(c). ...

Peter Neelands, Suzy Lendvay, "Valuation of IP based on a royalty stream", The Lawyer's Daily (LexisNexis Canada), January 24, 2018 -- summary under Other

Although this may serve as a useful starting point to begin consideration of the value of IP, courts have been reluctant to accept this methodology. ...

Kyle B. Lamothe, Alexander Demner, "Section 212.1 Post Mortem Pipeline Comfort Letter", Tax for the Owner-Manager, Vol. 20, No. 2, April 2020, p. 8 -- summary under Subsection 212.1(6)

Alternate transactions for life interest trusts (pp. 8-9) … Assume that the LIT transfers its shares of Opco for Holdco shares alone (that is, without receiving any non-share consideration). ...

Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27 -- summary under Subsection 219.1(1)

However, if the “amount” of the corporation’s debt obligation is equal to the principal amount of the debt ($100), it appears that the corporation could avoid departure tax for which it otherwise might be liable if the trading discount on the debt payable were taken into consideration, even though the net FMV of the debts receivable and payable, considered in isolation, is nil. ...

M. Elena Hoffstein, Corina S. Weigl, "Overview of the Twenty One Year Rule—A Trust Lawyer's Perspective", 2014 Ontario Tax Conference (Canadian Tax Foundation) -- summary under Subsection 104(6)

This method, however, is hampered by significant practical considerations. ...

Joint Committee, "Reportable Transaction and Notifiable Transaction Proposals", 5 April 2022 Joint Committee Submission -- summary under Subsection 237.4(5)

A similar “later of” concept should be employed federally and, given that many taxpayers operate in Québec, consideration should be given to coordinating deadlines. ...

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee -- summary under Excluded Interest

Consideration should be given to ways in which the rules canbe further adjusted to accommodate circumstances such as a joint-venture scenario in which each joint venturer funds its contribution to the venture mostly with loans from what is an eligible group corporation respecting it, with such loans being proportionate to their respective interests. ...

Clara Pham, "An Unpaid Amount Could Be an Upstream Loan", Canadian Tax Focus, Vol. 5, No. 3, August 2015, p.5. -- summary under Subsection 90(6)

On January 1, 2015, FA provides services to Canco in consideration for a fee. ...

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