Subsection 143.4(1) - Definitions
Right to reduce
Administrative Policy
26 May 2016 Internal T.I. 2016-0628741I7 - Interaction of s. 80 and s. 143.4
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Words and Phrases
exercisable| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a) | no settlement of debt under Plan before conditions precedent fulfilled | 158 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest only deductible in the year paid or payable | 159 |
| Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(4) | s. 143.4(4) caused an immediate income inclusion of prior years’ interest that was to be forgiven at a later date under an approved Plan of Compromise | 175 |
Chris Falk, Stefanie Morand and Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4," draft version of paper for CTF 2014 Conference Report.
Subsection 143.4(2) - Limitation of amount of expenditure
Administrative Policy
2016 Ruling 2016-0661071R3 - Whether s. 80 or s. 143.4 applies
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(4) | s. 80 rules prevailed in a CCAA compromise over the contingent amount (s. 143.4) rules | 300 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | presumption against double taxation applied to oust s. 143.4 | 56 |
S3-F6-C1 - Interest Deductibility
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10 October 2014 APFF Roundtable Q. 15, 2014-0538151C6 F - 2014 APFF Roundtable, Q. 15 - Section 143.4 & Reverse Earn-out
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Excluded Obligation | reverse earnout obligation of Buyco re Target was excluded obligation | 442 |
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36
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Subsection 143.4(4) - Subsequent years
Administrative Policy
2016 Ruling 2016-0661071R3 - Whether s. 80 or s. 143.4 applies
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(2) | s. 80 prevailed over s. 143.4 | 108 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | presumption against double taxation applied to oust s. 143.4 | 56 |
26 May 2016 Internal T.I. 2016-0628741I7 - Interaction of s. 80 and s. 143.4
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a) | no settlement of debt under Plan before conditions precedent fulfilled | 158 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest only deductible in the year paid or payable | 159 |
| Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(1) - Right to reduce | right to reduce notwithstanding that conditions precedent to interest forgiveness not yet satisfied | 311 |
Articles
Chris Falk, Stefanie Morand, Brian O'Neill, "Is there Always Certainty Regarding Tax Basis? – Limitations on Expenditures Pursuant to Sections 143.3 and 143.4", 2014 Conference Report, (Canadian Tax Foundation),14:1-36
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