Section 51.1

Administrative Policy

2014 Ruling 2013-0514191R3 - Debt restructuring, forgiveness and winding-up

underline;">: Currrent structure. Canco1 is obligated to its affiliate (Canco3) under non-interest-bearing U.S.-dollar debt evidenced by demand...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Principal Amount non-application of s. 39(2) to exchange of U.S.-dollar notes 142
Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) s. 51.1 exchange of U.S.-dollar notes 142
Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(f.1) 0
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(4) s. 51.1 exchange of U.S.-dollar notes and ATR-66 debt slide 430

2012 Ruling 2012-0451431R3 - Loss Consolidation

Ruling that s. 51.1 applied on conversion of one note into two new notes: a new senior and junior ranking note. See detailed summary under s....

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) ATR-66 elimination of debt to make Lossco solvent; roll-in/distribution out (one-day after roll in) of appreciated depreciables to use its losses 435
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition addition of conversion right 125
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(4) intercompany debt conversion to senior and junior note and elimination of junior note 326

2009 Ruling 2008-0300161R3 - Debt restructuring and forgiveness

underline;">: Background. Forco holds a non-interest-bearing note (the Forco Note) of its Parent, which is in CCAA proceedings, as its only...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(4) conversion and elimination of U.S. dollar note owing to partnership subsidiary 510

9 September 1997 External T.I. 9721405 - CONVERSION OF DEBT OBLIGATION

Where a debt obligation provides that it is convertible at the option of the holder into another debt obligation of the same issuer provided that...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) notice by issuer before convertible 95
Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) conversion conditional on issuer notice 173

13 February 1996 External T.I. 9532285 - US DOLLAR CONVERTIBLE DEBENTURE

Respecting whether s. 51.1 would apply to the conversion of a U.S.-dollar denominated convertible debenture, CRA noted that under s. 51.1(c) the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Principal Amount foreign currency principal 121

Articles

Didier Fr├ęchette, Ryan Rabinovitch, "Current Issues Involving Foreign Exchange", 2015 CTF Annual Conference paper

S. 51.1 applied to the conversion of US-dollar-denominated non-interest-bearing notes into US-dollar-denominated interest-bearing notes with the...

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Julie Colden, "Implications of Imperial Oil", Canadian Current Tax, Vol. 15, No. 3, December 2004, p. 21 at 26

[After discussing 9532285 above and Imperial Oil:] Based on Imperial Oil, it may no longer be correct to view the principal amount of a foreign...

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