Section 80

Subsection 80(2) (old)

Administrative Policy

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

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

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Subsection 80(1) - Definitions

See Also

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

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

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

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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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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

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9 September 2002 External T.I. 2002-014100 -

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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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92 C.M.TC - Q.14

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

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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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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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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

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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

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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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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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Excluded Obligation

See Also

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

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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

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

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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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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 -

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23 January 1996 External T.I. 5-952790 -

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19 January 1996 T.I. 952810 (C.T.O. "Forgiven Amount - Second Partnership Tier")

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Relevant loss balance

Administrative Policy

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

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Debtor

Cases

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

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See Also

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

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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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Words and Phrases
settle

See Also

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

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

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Words and Phrases
extinguish settle

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

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4 April 1997 T.I. 970436

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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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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

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

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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

1995 Alberta CICA Roundtable Q. 4, 7-951210 -

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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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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)(h) 47

Articles

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

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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

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

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Paragraph 80(2)(o)

Administrative Policy

2 October 1997 T.I. 972542

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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

Subsection 80(4) - Reductions of capital losses

Administrative Policy

92 C.M.TC - Q.15

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92 C.M.TC - Q.14

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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

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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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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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

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9 September 2002 External T.I. 2002-014100 -

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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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92 C.M.TC - Q.14

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

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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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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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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
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"

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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.

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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

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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.

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Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 0

Flynn, "Restructuring Financially Troubled Corporations", 1989 Conference Report, c. 19.

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Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 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(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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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

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

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Subsection 80(13) - Income inclusion

See Also

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

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Administrative Policy

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

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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.

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

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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
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