Section 143.4

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.

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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

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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.