Section 80

Subsection 80(2) (old)

Administrative Policy

93 C.P.T.J. - Q.38

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

3 June 1992 T.I. 913040 (May 1993 Access Letter, p. 198, ¶C76-067)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 80(1) - Definitions

See Also

Mitchell v. The Queen, 96 DTC o (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Hanson v. The Queen, 95 DTC 311 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Les aliments Kouri Inc. v. MNR, 93 DTC 35 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

National Trust Co. v. Mead, [1990] 5 WWR 455, [1990] 2 S.C.R. 410

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

2007 Ruling 2007-0245281R3 - windup of income trust on sale of assets:3rd party

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 110
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 86
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21) trustees making filings on behalf of terminated fund 48
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) assumed debt traceable to capital distribution 97
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) realization and distribution of target MFT gain 101
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 90

5 December 2003 External T.I. 2002-0165195 - Debt Forgiveness in Foreign Affiliates

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

9 September 2002 External T.I. 2002-0141005 - Debt forgiveness and capital contribution

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2 August 1994 External T.I. 9418055 - ECONOMIC DEFEASANCE

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 April 1994 T.I. (C.T.O. "Debtor's Gain on Settlement of Debt")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 36

93 C.R. - Q. 46

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 50

9 May 1994 Internal T.I. 9409347 - SHARES ISSUED FOR DEBT

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

92 C.R. - Q.18

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

92 C.M.TC - Q.14

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

91 CPTJ - Q.2

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 26

November 1991 Memorandum (Tax Window, No. 13, p. 17, ¶1581)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 16

23 October 1991 Memorandum (Tax Window, No. 12, p. 23, ¶1549)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 24

11 October 1991 Memorandum (Tax Window, No. 11, p. 22, ¶1518)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 83

10 July 1991 Decision Summary (Tax Window, No. 5, p. 12, ¶1346)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 59

26 June 1991 T.I. (Tax Window, No. 4, p. 8, ¶1317)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 89

3 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1062)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

8 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 10, ¶1046)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

90 C.P.T.J. - Q.5

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 54

11 June 1990 T.I. (November 1990 Access Letter, ¶1524)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

7 June 1990 T.I. (November 1990 Access Letter, ¶1522)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 26

10 April 1990 Memorandum (September 1990 Access Letter, ¶1421)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 20

30 October 89 T.I. (March 1990 Access Letter, ¶1146)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

89 C.M.TC - Q.21

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 10

88 C.R. - Q.14

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 21

87 C.R. - Q.58

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 43

86 C.R. - Q.60

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 15

80 C.R. - Q.38

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 15

80 C.R. Q.46

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 14

79 C.R. Q.27

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 81

IT-293R "Debtor's Gain on Settlement of Debt"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 0

IT-382 "Debts Bequeathed or Forgiven on Death"

Locations of other summaries Wordcount
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"

Locations of other summaries Wordcount
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.

Locations of other summaries Wordcount
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.

Durand, "Debt Restructuring for Companies in Financial Difficulty", Tax Aspects of Corporate Financing, CCH Seminars, September 13, 1990

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 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(5) 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(5) 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(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)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

9 April 2014 Internal T.I. 2014-0519231I7 - Debt forgiveness and guarantees

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) interest on guarantee obligation non-deductible 153

20 May 2014 External T.I. 2013-0516121E5 F - Debt forgiveness

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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) 157
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 157
Tax Topics - Income Tax Act - Section 248 - Subsection 248(26) unremitted GST and QST were not obligation "issued" by debtor 102
Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt BIA settlement of unremitted GST on sales was on capital account 82

Articles

Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Debtor

Cases

Metro Can Construction Ltd. v. The Queen, 2000 DTC 6495, 2001 FCA 227

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Metro-Can Construction Ltd. v. The Queen, 99 DTC 29 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Excluded Obligation

See Also

Denthor Developments Ltd. v. The Queen, 97 DTC 667 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(2) reverse earnout obligation of Buyco re Target shares 287

29 January 1997 External T.I. 9635975 - PARTNERSHIP TO SOLE PROPRIETOR

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

15 July 2009 External T.I. 2008-0289731E5 - Forgiveness of Accrued Interest

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph (a)

Administrative Policy

20 March 2017 External T.I. 2014-0545591E5 - Upstream Loan and Debt Forgiveness Rules

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(9) potential indefinite application of surplus where upstream loan forgiven after FA sale 203
Tax Topics - Income Tax Act - Section 90 - Subsection 90(14) debt forgiveness not a repayment 56

Forgiven Amount

See Also

Richer v. The Queen, 2009 DTC 1413, 2009 TCC 394

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

2016 Ruling 2016-0651621R3 - Partnership carried on by sole proprietor

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 198
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 93

2016 Ruling 2015-0623731R3 - Subsections 55(2) and (2.1)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) requirement to pro-rate PUC 576
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 136

13 January 2016 External T.I. 2015-0604521E5 - ACB increase in paragraph 55(3)(a) reorganization

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 423
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 173

2013 Ruling 2013-0498551R3 - Loss Consolidation

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 64

12 September 2012 Annual CTF Roundtable, 2012-0453381C6 - 2012 CICA Conference

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) forgiveness of unremitted GST 35
Tax Topics - Income Tax Act - Section 9 - Forgiveness of Debt forgiveness of source deductions on income account 108

28 November 2010 CTF Roundtable, 2010-0387451C6 - Debt forgiveness and Bankruptcy Annulment

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2010 Ruling 2009-0330901R3 - Reorganization of XXXXXXXXXX

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 432
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 100

2012 Ruling 2012-0452821R3 - Forgiveness of debt

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(4) debt elimination through drop-down, transfer and wind-up 205

20 April 2009 Internal T.I. 2008-0302511I7 - LYONS - Open Market Purchase

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 39 - Subsection 39(3) s. 80 does not apply to open market purchases 240

30 April 2004 External T.I. 2004-005753 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

23 January 1996 External T.I. 9527905 F - ARTICLE 79 ET 80

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

19 January 1996 External T.I. 9528105 - FORGIVEN AMOUNT - 2ND PARTNERSHIP TIER

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Relevant loss balance

Administrative Policy

7 October 2011 APFF Roundtable, 2010-0371941C6 F - Application de l'article 80 - fusion/liquidation

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 354

Subsection 80(2) - Application of debt forgiveness rules

Paragraph 80(2)(a)

Cases

Dieni v. The Queen, 2001 DTC 290 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 79 - Subsection 79(2) 100

Canada v. Diversified Holdings Ltd., 97 DTC 5203 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
settle

See Also

Central City Financial Services Ltd. v. The Queen, 98 DTC 1021 (TCC), aff'd 98 DTC 6645 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Carma Developers Ltd. v. The Queen, 96 DTC 1798 (TCC), briefly aff'd 96 DTC 6569 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Words and Phrases
extinguish settle

Administrative Policy

26 May 2016 Internal T.I. 2016-0628741I7 - Interaction of s. 80 and s. 143.4

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 163
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 323
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 185

12 October 2016 Internal T.I. 2016-0637781I7 - Employee loan or debt extinguished or settled

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 235

21 November 2014 External T.I. 2014-0535361E5 - Debt forgiveness rules

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

8 August 2014 External T.I. 2014-0524951E5 - Debt forgiveness; liability on dissolution

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80.01 - Subsection 80.01(8) s. 50 write-down triggers deemed forgiveness 160

2 August 1994 T.I. 941805

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

4 April 1997 External T.I. 9704365 - APPLICATION OF SECTION 80

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 80(2)(b)

Administrative Policy

13 June 2011 External T.I. 2011-0393561E5 - Debt forgiveness

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

15 July 2009 External T.I. 2008-0289731E5 - Forgiveness of Accrued Interest

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 80(2)(g)

See Also

Corner Brook Pulp and Paper Limited (Formerly Deer Lake Power Company Limited) v. The Queen, 2006 DTC 2329, 2006 TCC 70

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

King Rentals Ltd. v. The Queen, 96 DTC 1132 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

10 March 1999 External T.I. 9829125 - PRICE ADJUSTMENT CLAUSE & 80(2)(G)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date 36

Paragraph 80(2)(h)

Administrative Policy

28 February 1996 External T.I. 9601795 - FOREIGN EXCHANGE LOSS

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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 49
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(k) 49

24 May 1995 CICA Roundtable Q. 4, 9512100 - DEBT FORGIVENESS

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 80(2)(k)

Administrative Policy

2009 Ruling 2009-0313921R3 - Wind-up of creditor into debtor

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

28 February 1996 External T.I. 9601795 - FOREIGN EXCHANGE LOSS

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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 49
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(h) 49

Articles

Carrie Aiken, Johnson Tai, "Debt Restructuring Transactions – Issues, Strategies and Trends", 2016 CTF Annual Conference draft paper

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Didier Fréchette, Ryan Rabinovitch, "Current Issues Involving Foreign Exchange", 2015 CTF Annual Conference paper

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Carrie Smit, "Debt Restructuring and the Falling Canadian Dollar"

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 39 - Subsection 39(2) 132

Thomas A. Bauer, "Restructuring Debt Obligations", 2008 Conference Report

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Paragraph 80(2)(o)

Administrative Policy

2 October 1997 External T.I. 9725425 - FORGIVENESS OF ONE JOINT DEBTOR

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 80(3) - Reductions of non-capital losses

Administrative Policy

17 June 2003 External T.I. 2002-0178255 - FORGIVENESS OF DEBT DEBT AFTER AOC+AMALG

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Paragraph 80(3)(a)

Administrative Policy

23 May 2012 Internal T.I. 2011-0418071I7 F - Remise de dettes, PAC

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 223

Subsection 80(4) - Reductions of capital losses

Administrative Policy

92 C.M.TC - Q.15

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

92 C.M.TC - Q.14

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

11 June 1991 T.I. (Tax Window, No. 4, p. 8, ¶1297)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) 48

Articles

Subsection 80(5) - Reductions with respect to depreciable property

See Also

Richer v. The Queen, 2009 DTC 1413, 2009 TCC 394

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

MNR v. Mid-West Abrasive Co. of Canada Ltd., 73 DTC 5429, [1973] CTC 548 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 110
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 86
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21) trustees making filings on behalf of terminated fund 48
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) assumed debt traceable to capital distribution 97
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) realization and distribution of target MFT gain 101
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 90

5 December 2003 External T.I. 2002-0165195 - Debt Forgiveness in Foreign Affiliates

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

9 September 2002 External T.I. 2002-0141005 - Debt forgiveness and capital contribution

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

2 August 1994 External T.I. 9418055 - ECONOMIC DEFEASANCE

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 April 1994 T.I. (C.T.O. "Debtor's Gain on Settlement of Debt")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 36

93 C.R. - Q. 46

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 50

9 May 1994 Internal T.I. 9409347 - SHARES ISSUED FOR DEBT

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

92 C.R. - Q.18

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

92 C.M.TC - Q.14

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

91 CPTJ - Q.2

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 26

November 1991 Memorandum (Tax Window, No. 13, p. 17, ¶1581)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 16

23 October 1991 Memorandum (Tax Window, No. 12, p. 23, ¶1549)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 24

11 October 1991 Memorandum (Tax Window, No. 11, p. 22, ¶1518)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 83

10 July 1991 Decision Summary (Tax Window, No. 5, p. 12, ¶1346)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 59

26 June 1991 T.I. (Tax Window, No. 4, p. 8, ¶1317)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 89

3 December 1990 T.I. (Tax Window, Prelim. No. 2, p. 11, ¶1062)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

8 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 10, ¶1046)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

90 C.P.T.J. - Q.5

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 54

11 June 1990 T.I. (November 1990 Access Letter, ¶1524)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

7 June 1990 T.I. (November 1990 Access Letter, ¶1522)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 26

10 April 1990 Memorandum (September 1990 Access Letter, ¶1421)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 20

30 October 89 T.I. (March 1990 Access Letter, ¶1146)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

89 C.M.TC - Q.21

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 10

88 C.R. - Q.14

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 21

87 C.R. - Q.58

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 43

86 C.R. - Q.60

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 15

80 C.R. - Q.38

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 15

80 C.R. Q.46

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 14

79 C.R. Q.27

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 81

IT-293R "Debtor's Gain on Settlement of Debt"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 0

IT-382 "Debts Bequeathed or Forgiven on Death"

Locations of other summaries Wordcount
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
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.

Durand, "Debt Restructuring for Companies in Financial Difficulty", Tax Aspects of Corporate Financing, CCH Seminars, September 13, 1990

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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 345

10 January 2011 External T.I. 2010-0371021E5 - Debt forgiveness - 80(9)(a)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 80(13) - Income inclusion

See Also

GKN Sinter Metals - St. Thomas Ltd. v. The Queen, 2006 DTC 3025, 2006 TCC 248

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

2 September 2009 Internal T.I. 2009-0329251I7 F - Application du paragraphe 80(16)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(16) s. 80(16) designation under s. 80(11) increased s. 80(13) income inclusion 215
Tax Topics - Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss - A s. 61.3 deduction reduced non-capital loss 293

2 June 2003 External T.I. 2003-0002485 - DEBT FORGIVENESS-GIFT FUND

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Bernstein, "Update on Debt Forgiveness - Part I", Tax Profile, Vol. 4, No. 25, July 1995, p. 269.

Ahmed, "Debt Forgiveness Rules and Share Purchase Transactions", Canadian Current Tax, March 1995, Vol. 5, No. 6, p. 58.

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Sulbsection 80(15)

Administrative Policy

22 March 2017 External T.I. 2016-0666481E5 - Debt forgiveness in a tiered partnership

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
Locations of other summaries Wordcount
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 202

Subsection 80(16)

Administrative Policy

2 September 2009 Internal T.I. 2009-0329251I7 F - Application du paragraphe 80(16)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.
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 293
Tax Topics - Income Tax Act - Section 80 - Subsection 80(13) s. 80(13) income was from the debtor's business 30