Section 50

Subsection 50(1) - Debts established to be bad debts and shares of bankrupt corporation

Cases

Sunatori v. Canada, 2011 DTC 5153 [at 6175], 2011 FCA 254

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Simmonds v. Canada (Minister of National Revenue), 2006 DTC 6083, 2006 FC 130

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Turner v. The Queen, 2000 DTC 6442, 2001 FCA 289, 2001 FCA 33 (FCA)

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See Also

Kokai-Kuun Estate v. The Queen, 2015 TCC 217

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base interest carrying charges on vacant land not added to ACB 76

Gaumond v. The Queen, 2014 DTC 1024 [at 98], 2014 TCC 339 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) renounced debt is not disposed of to anyone/s. 50 not available where debt settled in year 261
Tax Topics - Income Tax Act - Section 84 - Subsection 84(9) s. 84(9) not for greater certainty 123

St-Hilaire v. The Queen, 2014 TCC 336 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) acceptance of bankruptcy proposal caused debt to disappear before taxpayer's year end 216

Coveley v. The Queen, 2014 DTC 1041 [at 2771], 2013 TCC 417, aff'd 2014 FCA 281

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) write-off of loans from shareholder v. employee/spouse 150

Kyriazakos v. The Queen, 2007 DTC 373, 2007 TCC 66

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Netolitzky v. The Queen, 2006 DTC 2953, 2006 TCC 172

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Hopmeyer v. The Queen, 2006 DTC 2919, 2006 TCC 185

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Litowitz v. The Queen, 2005 DTC 1469, 2005 TCC 557

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Keating v. The Queen, 2005 DTC 743, 2005 TCC 296 (Informal Procedure)

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Jacques St-Onge Inc. v. The Queen, 2003 DTC 153 (TCC)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention 93

Campbell v. The Queen, 2000 DTC 2528 (TCC)

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Burns v. The Queen, 94 DTC 1370 (TCC)

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Administrative Policy

S4-F8-C1 - Business Investment Losses

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17 October 2014 Internal T.I. 2014-0535121I7 F - Hypothèque et créance irrécouvrable

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11 October 2013 APFF Roundtable, 2013-0495671C6 F - Déduction d'une partie d'une créance irrécouvrable

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) 20(1)(p)(i) deduction for trade debts of a customer are determined on a receivable by receivable basis 133

3 January 2014 External T.I. 2013-0482081E5 - Nil value partnership units

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition nil value partnership 93

9 November 2012 CTF Atlantic Roundtable, 2012-0465981C6 - CTF Atlantic - Filing Electronically

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5 October 2012 APFF Roundtable, 2012-0454061C6 F - Transfer of a Lossco to a related corporation

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares non-capital losses taken into account 152
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) related but not affiliated transfer of Lossco shares to father's or brother's company 209
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) 208

16 December 2003 Internal T.I. 2003-04616 -

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares 104

8 January 2002 External T.I. 2001-009600 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation old trade receivable may not be active 65

15 June 1998 Memorandum 980234

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Words and Phrases
insolvent

1994 A.P.F.F. Round Table, Q. 6

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6 April 1993 T.I. (Tax Window, No. 30, p. 5, ¶2493)

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Words and Phrases
debt

Central Region Rulings Directorate Seminar, Q. A (May 1993 Access Letter, p. 228)

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17 February 1993 Memorandum 930202 (Tax Window, No. 30, p. 21, ¶2496)

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1992 A.P.F.F. Annual Conference, Q. 4 (January - February 1993 Access Letter, p. 51)

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23 October 1991 Memorandum (Tax Window, No. 12, p. 23, ¶1548)

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29 July 1991 T.I. (Tax Window, No. 7, p. 19, ¶1377)

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12 December 1989 T.I. (May 1990 Access Letter, ¶1215)

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25 October 89 T.I. (March 1990 Access Letter, ¶1145)

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IT-159R3 "Capital Debts Established to be Bad Debts"

Paragraph 50(1)(a)

Administrative Policy

S4-F8-C1 - Business Investment Losses

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Paragraph 50(1)(b)

Subparagraph 50(1)(b)(iii)

Subsection 50(1.1)

Administrative Policy

S4-F8-C1 - Business Investment Losses

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