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