Subsection 80(2) (old)
Administrative Policy
93 C.P.T.J. - Q.38
Subsection 80(1) - Definitions
See Also
Mitchell v. The Queen, 96 DTC o (TCC)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(14) | 47 | |
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) | 113 |
Hanson v. The Queen, 95 DTC 311 (TCC)
Les aliments Kouri Inc. v. MNR, 93 DTC 35 (TCC)
National Trust Co. v. Mead, [1990] 5 WWR 455, [1990] 2 S.C.R. 410
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | assumption of loan did not entail its novation | 188 |
MNR v. Mid-West Abrasive Co. of Canada Ltd., 73 DTC 5429, [1973] CTC 548 (FCTD)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 109 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 74 |
Administrative Policy
2007 Ruling 2007-0245281R3 - windup of income trust on sale of assets:3rd party
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| Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.3) | capital loss on redemption of trust units following distribution of most of its assets including as capital gains distribution | 106 |
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(h) - Subparagraph 53(2)(h)(i.1) | no ACB reduction for capital gains distribution by unit trust to bidco | 84 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21) | trustees making filings on behalf of terminated fund | 46 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | assumed debt traceable to capital distribution | 93 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) | realization and distribution of target MFT gain | 99 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 86 |
5 December 2003 External T.I. 2002-0165195 - Debt Forgiveness in Foreign Affiliates
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| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(c) | debt forgiveness as contribution to CFA | 96 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 132 | |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(g.1) | 76 | |
| Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings | 61 | |
| Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(2) - Paragraph 5907(2)(f) | forgiveness gain did not relate to active business items | 121 |
9 September 2002 External T.I. 2002-014100 -
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| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | 35 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 50 |
2 August 1994 T.I. 941805 (C.T.O. "Economic Defeasance")
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 50 |
5 April 1994 T.I. (C.T.O. "Debtor's Gain on Settlement of Debt")
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 34 |
93 C.R. - Q. 46
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 50 |
9 May 1994 Memorandum 940934 (C.T.O. "Shares Issued for Debt")
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 42 |
92 C.R. - Q.18
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 27 | |
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) | 27 |
92 C.M.TC - Q.14
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(4) | 55 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 55 |
91 CPTJ - Q.2
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 26 |
November 1991 Memorandum (Tax Window, No. 13, p. 17, ¶1581)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 16 |
23 October 1991 Memorandum (Tax Window, No. 12, p. 23, ¶1549)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 24 |
11 October 1991 Memorandum (Tax Window, No. 11, p. 22, ¶1518)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 83 |
10 July 1991 Decision Summary (Tax Window, No. 5, p. 12, ¶1346)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 59 |
26 June 1991 T.I. (Tax Window, No. 4, p. 8, ¶1317)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 85 |
3 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1062)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 32 | |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) | 21 |
8 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 10, ¶1046)
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| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(a) | 25 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 25 |
90 C.P.T.J. - Q.5
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 54 |
11 June 1990 T.I. (November 1990 Access Letter, ¶1524)
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| Tax Topics - Income Tax Act - Section 79 | 77 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 77 | |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(5.1) | 77 |
7 June 1990 T.I. (November 1990 Access Letter, ¶1522)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 24 |
10 April 1990 Memorandum (September 1990 Access Letter, ¶1421)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 20 |
30 October 89 T.I. (March 1990 Access Letter, ¶1146)
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| Tax Topics - Income Tax Act - Section 54 - Capital Property | 28 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 29 |
89 C.M.TC - Q.21
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 10 |
88 C.R. - Q.14
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 21 |
87 C.R. - Q.58
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 43 |
86 C.R. - Q.60
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 15 |
80 C.R. - Q.38
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 15 |
80 C.R. Q.46
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 14 |
79 C.R. Q.27
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 81 |
IT-293R "Debtor's Gain on Settlement of Debt"
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|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 0 |
IT-382 "Debts Bequeathed or Forgiven on Death"
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|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 0 |
IT-239R2 "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-arm's Length Circumstances" under "Application of Section 80"
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 0 |
Articles
Schafer, "Tax Implications of Restructuring and Refinancing", 1992 Corporate Management Tax Conference Report, c. 4.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 0 |
Wertschek, "Application of a Corporation's Indebtedness to the Issue Price of its Shares Constitutes the Full Payment of the Debt", Corporate Structures and Groups, Vol. 1, No. 2, 1992, p. 16
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 0 |
Frankovic, "Taxing Times: Foreclosures, Default Sales, Debt Forgiveness, Doubtful and Bad Debts", 1991 Canadian Tax Journal, p. 889.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | 0 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 0 |
Durand, "Debt Restructuring for Companies in Financial Difficulty", Tax Aspects of Corporate Financing, CCH Seminars, September 13, 1990
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 27 |
Brussa, "Strategies for Troubled Times", 1990 Conference Report, c. 17.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 0 |
Flynn, "Restructuring Financially Troubled Corporations", 1989 Conference Report, c. 19.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 0 |
Couzin, "Debt Restructuring", 1986 Corporate Management Tax Conference Report, p. 140.
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 0 |
Commercial Debt Obligation
See Also
Genex Communications inc. v. The Queen, 2010 DTC 1064 [at 2840], 2009 TCC 583, rev'd 2011 DTC 5061 [at 5707], 2010 FCA 353)
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| Tax Topics - Statutory Interpretation - French and English Version | 60 |
Administrative Policy
9 April 2014 Internal T.I. 2014-0519231I7 - Debt forgiveness and guarantees
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | interest on guarantee obligation non-deductible | 149 |
20 May 2014 External T.I. 2013-0516121E5 F - Debt forgiveness
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv) | BIA settlement of GST interest and penalties included under s. 12(1)(x)(iv) | 149 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(2.2) | s. 12(1)(x)(iv) inclusion from BIA settlement of GST interest and penalties could be offset against related expense | 149 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(26) | unremitted GST and QST were not obligation "issued" by debtor | 94 |
| Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt | BIA settlement of unremitted GST on sales was on capital account | 78 |
Articles
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper
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Debtor
Cases
Metro Can Construction Ltd. v. The Queen, 2000 DTC 6495, 2001 FCA 227
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| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 45(3) | 97 |
See Also
Excluded Obligation
See Also
Denthor Developments Ltd. v. The Queen, 97 DTC 667 (TCC)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt | settlement of financing of land inventory on capital account | 57 |
Administrative Policy
10 October 2014 APFF Roundtable Q. 15, 2014-0538151C6 F - 2014 APFF Roundtable, Q. 15 - Section 143.4 & Reverse Earn-out
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| Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(2) | reverse earnout obligation of Buyco re Target shares | 275 |
29 January 1997 T.I. 963597
15 July 2009 External T.I. 2008-0289731E5 - Forgiveness of Accrued Interest
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| Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt | purpose and effect of forgiveness | 48 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(b) | 185 |
Paragraph (a)
Administrative Policy
20 March 2017 External T.I. 2014-0545591E5 - Upstream Loan and Debt Forgiveness Rules
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| Tax Topics - Income Tax Act - Section 90 - Subsection 90(9) | potential indefinite application of surplus where upstream loan forgiven after FA sale | 187 |
| Tax Topics - Income Tax Act - Section 90 - Subsection 90(14) | debt forgiveness not a repayment | 54 |
Forgiven Amount
See Also
Richer v. The Queen, 2009 DTC 1413, 2009 TCC 394
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| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 106 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 83 |
Administrative Policy
2016 Ruling 2016-0651621R3 - Partnership carried on by sole proprietor
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| Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) | the assumption by a partner of a debt owing to it by a partnership bumped the partner’s ACB | 182 |
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) | ACB increased by assumption of debt owing to partner by partnership | 89 |
2016 Ruling 2015-0623731R3 - Subsections 55(2) and (2.1)
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| Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) | requirement to pro-rate PUC | 530 |
| Tax Topics - Income Tax Act - Section 86 - Subsection 86(1) | stated capital of old shares required to be prorated amongst new classes based on relative FMV | 130 |
13 January 2016 External T.I. 2015-0604521E5 - ACB increase in paragraph 55(3)(a) reorganization
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| Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) | GAAR may be applied if the transactions produce an outside basis step-up | 372 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | objectionable for a s. 55(3)(a) spin-off to result in an increase in the aggregate outside basis | 169 |
2013 Ruling 2013-0498551R3 - Loss Consolidation
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| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | loss shift to parent/loans to parent used to redeem prefs/no borrowing capacity rep | 62 |
12 September 2012 Annual CTF Roundtable, 2012-0453381C6 - 2012 CICA Conference
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| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | forgiveness of unremitted GST | 33 |
| Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt | forgiveness of source deductions on income account | 102 |
28 November 2010 CTF Roundtable, 2010-0387451C6 - Debt forgiveness and Bankruptcy Annulment
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2010 Ruling 2009-0330901R3 - Reorganization of XXXXXXXXXX
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| Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(h) - Subparagraph 53(2)(h)(i.1) | no ACB reduction for capital gain distributed to Trust parent on repurchase of most Trust units notwithstanding parent amalgamation before Trust year end | 408 |
| Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2.1) | recognition of capital loss on distribution of capital gain through redemption of most of trust units by corporate unitholder | 98 |
2012 Ruling 2012-0452821R3 - Forgiveness of debt
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| Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(4) | debt elimination through drop-down, transfer and wind-up | 159 |
20 April 2009 Internal T.I. 2008-0302511I7 - LYONS - Open Market Purchase
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| Tax Topics - Income Tax Act - Section 39 - Subsection 39(3) | s. 80 does not apply to open market purchases | 232 |
30 April 2004 External T.I. 2004-005753 -
23 January 1996 External T.I. 5-952790 -
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| Tax Topics - Income Tax Act - Section 79.1 - Subsection 79.1(6) | 19 | |
| Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(8) | 15 |
Relevant loss balance
Administrative Policy
7 October 2011 APFF Roundtable, 2010-0371941C6 F - Application de l'article 80 - fusion/liquidation
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| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) - Paragraph 88(1.1)(e) | fiction in s. 80(13) is insufficient to preserve non-capital losses of a subsidiary from a business that ceased following an AOC where subsidiary wound-up and parent has forgiven amount | 344 |
Subsection 80(2) - Application of debt forgiveness rules
Paragraph 80(2)(a)
Cases
Dieni v. The Queen, 2001 DTC 290 (TCC)
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| Tax Topics - Income Tax Act - Section 79 - Subsection 79(2) | 100 |
Canada v. Diversified Holdings Ltd., 97 DTC 5203 (FCA)
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| Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a) | 138 |
See Also
Central City Financial Services Ltd. v. The Queen, 98 DTC 1021 (TCC), aff'd 98 DTC 6645 (FCA)
Carma Developers Ltd. v. The Queen, 96 DTC 1798 (TCC), briefly aff'd 96 DTC 6569 (FCA)
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | 147 |
Administrative Policy
26 May 2016 Internal T.I. 2016-0628741I7 - Interaction of s. 80 and s. 143.4
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest only deductible in the year paid or payable | 159 |
| Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(1) - Right to reduce | right to reduce notwithstanding that conditions precedent to interest forgiveness not yet satisfied | 311 |
| Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(4) | s. 143.4(4) caused an immediate income inclusion of prior years’ interest that was to be forgiven at a later date under an approved Plan of Compromise | 175 |
12 October 2016 Internal T.I. 2016-0637781I7 - Employee loan or debt extinguished or settled
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| Tax Topics - Income Tax Act - Section 6 - Subsection 6(15) | writing-off a statute-barred debt of an employee or remitting for financial hardship triggers benefit | 213 |
21 November 2014 External T.I. 2014-0535361E5 - Debt forgiveness rules
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8 August 2014 External T.I. 2014-0524951E5 - Debt forgiveness; liability on dissolution
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| Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(8) | s. 50 write-down triggers deemed forgiveness | 152 |
2 August 1994 T.I. 941805
Paragraph 80(2)(b)
Administrative Policy
13 June 2011 External T.I. 2011-0393561E5 - Debt forgiveness
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15 July 2009 External T.I. 2008-0289731E5 - Forgiveness of Accrued Interest
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Excluded Obligation | 60 | |
| Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt | purpose and effect of forgiveness | 48 |
Paragraph 80(2)(g)
See Also
Administrative Policy
10 March 1999 External T.I. 5-982912 -
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| Tax Topics - General Concepts - Effective Date | 34 |
Paragraph 80(2)(h)
Administrative Policy
28 February 1996 TI 960179
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) | s. 39(2) rather than s. 80 applicable to replacement with C$ obligation | 47 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(k) | 47 |
Articles
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper
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Paragraph 80(2)(k)
Administrative Policy
2009 Ruling 2009-0313921R3 - Wind-up of creditor into debtor
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| Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(4) | 35 |
28 February 1996 TI 960179
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| Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) | s. 39(2) rather than s. 80 applicable to replacement with C$ obligation | 47 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(h) | 47 |
Articles
Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper
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| Tax Topics - Income Tax Act - Section 39 - Subsection 39(2.02) | 115 | |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(12) | 147 | |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 283 |
Didier Fréchette, Ryan Rabinovitch, "Current Issues Involving Foreign Exchange", 2015 CTF Annual Conference paper
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Carrie Smit, "Debt Restructuring and the Falling Canadian Dollar"
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| Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) | 132 |
Paragraph 80(2)(o)
Subsection 80(3) - Reductions of non-capital losses
Administrative Policy
17 June 2003 External T.I. 2002-017825 -
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| Tax Topics - Income Tax Act - Section 87 - Subsection 87(2.1) | 90 |
Articles
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper
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Paragraph 80(3)(a)
Administrative Policy
23 May 2012 Internal T.I. 2011-0418071I7 F - Remise de dettes, PAC
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| Tax Topics - Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss - D.2 | debt settlement results in immediate application of forgiven amount to reduce NCL at that time | 215 |
Subsection 80(4) - Reductions of capital losses
Administrative Policy
92 C.M.TC - Q.15
92 C.M.TC - Q.14
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 55 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) | 55 |
11 June 1991 T.I. (Tax Window, No. 4, p. 8, ¶1297)
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | 46 |
Articles
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper
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Subsection 80(5) - Reductions with respect to depreciable property
See Also
Richer v. The Queen, 2009 DTC 1413, 2009 TCC 394
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 163 - Subsection 163(2) | 106 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount | 116 |
MNR v. Mid-West Abrasive Co. of Canada Ltd., 73 DTC 5429, [1973] CTC 548 (FCTD)
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 109 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | indefinite payment arrangements for interest | 74 |
Administrative Policy
2007 Ruling 2007-0245281R3 - windup of income trust on sale of assets:3rd party
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.3) | capital loss on redemption of trust units following distribution of most of its assets including as capital gains distribution | 106 |
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(h) - Subparagraph 53(2)(h)(i.1) | no ACB reduction for capital gains distribution by unit trust to bidco | 84 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21) | trustees making filings on behalf of terminated fund | 46 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | assumed debt traceable to capital distribution | 93 |
| Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) | realization and distribution of target MFT gain | 99 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 86 |
5 December 2003 External T.I. 2002-0165195 - Debt Forgiveness in Foreign Affiliates
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(c) | debt forgiveness as contribution to CFA | 96 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 132 | |
| Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(g.1) | 76 | |
| Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings | 61 | |
| Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(2) - Paragraph 5907(2)(f) | forgiveness gain did not relate to active business items | 121 |
9 September 2002 External T.I. 2002-014100 -
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|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | 35 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 50 |
2 August 1994 T.I. 941805 (C.T.O. "Economic Defeasance")
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 50 |
5 April 1994 T.I. (C.T.O. "Debtor's Gain on Settlement of Debt")
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 34 |
93 C.R. - Q. 46
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 50 |
9 May 1994 Memorandum 940934 (C.T.O. "Shares Issued for Debt")
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 42 |
92 C.R. - Q.18
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 27 | |
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1.1) | 27 |
92 C.M.TC - Q.14
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 55 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(4) | 55 |
91 CPTJ - Q.2
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 26 |
November 1991 Memorandum (Tax Window, No. 13, p. 17, ¶1581)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 16 |
23 October 1991 Memorandum (Tax Window, No. 12, p. 23, ¶1549)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 24 |
11 October 1991 Memorandum (Tax Window, No. 11, p. 22, ¶1518)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 83 |
10 July 1991 Decision Summary (Tax Window, No. 5, p. 12, ¶1346)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 59 |
26 June 1991 T.I. (Tax Window, No. 4, p. 8, ¶1317)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 85 |
3 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1062)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 32 | |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(1.1) | 21 |
8 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 10, ¶1046)
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| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(a) | 25 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 25 |
90 C.P.T.J. - Q.5
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 54 |
11 June 1990 T.I. (November 1990 Access Letter, ¶1524)
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| Tax Topics - Income Tax Act - Section 79 | 77 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 77 | |
| Tax Topics - Income Tax Act - Section 85 - Subsection 85(5.1) | 77 |
7 June 1990 T.I. (November 1990 Access Letter, ¶1522)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 24 |
10 April 1990 Memorandum (September 1990 Access Letter, ¶1421)
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 20 |
30 October 89 T.I. (March 1990 Access Letter, ¶1146)
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| Tax Topics - Income Tax Act - Section 54 - Capital Property | 28 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 29 |
89 C.M.TC - Q.21
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 10 |
88 C.R. - Q.14
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 21 |
87 C.R. - Q.58
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 43 |
86 C.R. - Q.60
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 15 |
80 C.R. - Q.38
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 15 |
80 C.R. Q.46
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 14 |
79 C.R. Q.27
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 81 |
IT-293R "Debtor's Gain on Settlement of Debt"
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|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 0 |
IT-382 "Debts Bequeathed or Forgiven on Death"
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|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 0 |
IT-239R2 "Deductibility of Capital Losses from Guaranteeing Loans for Inadequate Consideration and from Loaning Funds at less than a Reasonable Rate of Interest in Non-arm's Length Circumstances" under "Application of Section 80"
| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 0 |
Articles
Schafer, "Tax Implications of Restructuring and Refinancing", 1992 Corporate Management Tax Conference Report, c. 4.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 0 |
Wertschek, "Application of a Corporation's Indebtedness to the Issue Price of its Shares Constitutes the Full Payment of the Debt", Corporate Structures and Groups, Vol. 1, No. 2, 1992, p. 16
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 0 |
Frankovic, "Taxing Times: Foreclosures, Default Sales, Debt Forgiveness, Doubtful and Bad Debts", 1991 Canadian Tax Journal, p. 889.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | 0 | |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 0 |
Durand, "Debt Restructuring for Companies in Financial Difficulty", Tax Aspects of Corporate Financing, CCH Seminars, September 13, 1990
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 27 |
Brussa, "Strategies for Troubled Times", 1990 Conference Report, c. 17.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 0 |
Flynn, "Restructuring Financially Troubled Corporations", 1989 Conference Report, c. 19.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 0 |
Couzin, "Debt Restructuring", 1986 Corporate Management Tax Conference Report, p. 140.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) | 0 |
Subsection 80(9) - Reductions of adjusted cost bases of capital properties
Administrative Policy
22 March 2017 External T.I. 2016-0666481E5 - Debt forgiveness in a tiered partnership
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 80 - Sulbsection 80(15) | double application of s. 80(15) and dovetailing with s. 80(9) where lower-tier partnership is wound-up into upper-tier partnership | 335 |
Subsection 80(13) - Income inclusion
See Also
Administrative Policy
2 September 2009 Internal T.I. 2009-0329251I7 F - Application du paragraphe 80(16)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(16) | s. 80(16) designation under s. 80(11) increased s. 80(13) income inclusion | 209 |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss - A | s. 61.3 deduction reduced non-capital loss | 281 |
2 June 2003 External T.I. 2003-000248 -
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | 72 |
Articles
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper
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Bernstein, "Update on Debt Forgiveness - Part I", Tax Profile, Vol. 4, No. 25, July 1995, p. 269.
Sulbsection 80(15)
Administrative Policy
22 March 2017 External T.I. 2016-0666481E5 - Debt forgiveness in a tiered partnership
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(9) | on wind-up of lower-tier partnership, ACB bump from its s. 80(13) forgeiveness income is included | 196 |
Subsection 80(16)
Administrative Policy
2 September 2009 Internal T.I. 2009-0329251I7 F - Application du paragraphe 80(16)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss - A | s. 61.3 deduction reduced non-capital loss | 281 |
| Tax Topics - Income Tax Act - Section 80 - Subsection 80(13) | s. 80(13) income was from the debtor's business | 28 |