Section 51.1

Administrative Policy

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

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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 123
Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) s. 51.1 exchange of U.S.-dollar notes 123
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 372

2012 Ruling 2012-0451431R3 - Loss Consolidation

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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 377
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition addition of conversion right 115
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 276

2009 Ruling 2008-0300161R3 - Debt restructuring and forgiveness

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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 444

9 September 1997 T.I. 9721405 [conversion subject to issuer notice]

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13 February 1996 T.I. 9532285 [foreign currency principal]

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Principal Amount foreign currency principal 115

Articles

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

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

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