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...
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....
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...
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...
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...
Articles
Didier Fréchette, 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...
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...