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Accordingly, planning to utilize or move other more valuable tax attributes prior to the debt forgiveness should be considered. ...

Subsection 248(26) provides, inter alia, that for the purpose of applying the provision of the ITA relating to the treatment of the debtor in repect of the liability, any amount that a debtor becomes liable to pay that is otherwise deductible in computing the debtor's income will be considered to be an obligation issued by the debtor having a principal amount equal to the amount of the liability. … [T]o conclude that any such obligation constitutes a commercial debt obligation, one must conclude that interest would be deductible if it were payable on the obligation. ...

Companies in the trucking business are particularly likely to be in this situation, since the use of a state's road system could be considered sufficient nexus for taxation. ...

Since paragraph (d) of the EP definition deems LP1 to be a corporation, it is suggested that Forhold 2, and consequently Canco, could be considered to be related to LP1 on the basis that Forhold 2 controls LP1. ...

Kandev, Sandra Slaats, "Recent Developments in the Foreign Affiliate Area", 2015 Annual CTF Conference paper-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation CRA position on partnerships under the Delaware Revised Uniform Partnership Act (p. 31:5) Effectively, the CRA concluded [in ITTN No. 20, June 14, 2001, see also 2004-0104691E5] that the existence of a separate-legal-entity clause in Delaware partnership legislation would not, in itself, prevent a business association from being considered a partnership for Canadian tax purposes. ...

Kandev, Sandra Slaats, "Recent Developments in the Foreign Affiliate Area", 2015 Annual CTF Conference paper-- summary under Section 96 Summary Under Tax Topics- Income Tax Act- Section 96 CRA position on partnerships under the Delaware Revised Uniform Partnership Act (p. 31:5) Effectively, the CRA concluded [in] ITTN No. 20, June 14, 2001, see also 2004-0104691E5] that the existence of a separate-legal-entity clause in Delaware partnership legislation would not, in itself, prevent a business association from being considered a partnership for Canadian tax purposes. ...

On the basis of the historical position of the CRA, this would be the day on which the shares were issued, although it could be argued—given that the definition of PUC specifies that it is an amount that is to be determined "at any particular time"—that the PUC in respect of the shares should be considered to arise from time to time (that is, at any time that it is calculated). … [A]ccording to [9634245], it is not possible to specify an amount in foreign currency. … [T]his interpretation is arguably inconsistent with the tax policy underlying subsections 191(4) and (5)… [and] with [CRA's] position regarding the application of section 51.1.... ...

The amount of the deferred purchase price is considered to be a separate property, and any further recovery or loss is recognized when amounts are received from the SPE. ...

Changes to the current generally accepted accounting principles, effective for fiscal years beginning after calendar 2020, must be considered from a tax perspective…. ...

But under the assignment rules, the assignor can assign only up to a maximum amount….the assignment may be considered invalid, and the result could be that none of Serviceco's service income will be eligible for the SBD…. ...