Section 62.1
Paragraph 62.1(b)
Subparagraph 62.1(b)(ii)
Administrative Policy
Pending Default of a Proposal under the BIA where the Canada Revenue Agency is a majority creditor: April 23, 2020 OSB Webpage
COVID-19 context
The CRA has heard from Licensed Insolvency Trustees (LITs) and the Office of the Superintendent of Bankruptcy (OSB) about debtors...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 224 - Subsection 224(1.2) | deferral of payments under a Bankruptcy proposal until September 1, 2020 | 180 |
Section 50.6
Subsection 50.6(3)
Cases
Attorney General of Canada v. Richter Advisory Group Inc., 2023 QCCA 1295
On October 26. 2021, two debtors filed a notice of intention to make a proposal pursuant to s. 50.4 of the Bankruptcy and Insolvency Act...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 227 - Subsection 227(4.1) | s. 227(4.1) could be subordinated by court for super-priority interim financing re proposal in bankruptcy | 328 |
Section 69
Subsection 69(4)
Administrative Policy
2 November 2023 APFF Roundtable Q. 13, 2023-0982941C6 F - APFF - Congrès 2023 - Table ronde sur la fiscalité
Trustee of Girard, 2014 QCCA 1922, stated, in connection with the Bankruptcy and Insolvency Act ("B.I.A.") and CRA notices of assessment:
[68] In...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | stay of proceedings under the BIA is a procedural limitation that does not affect an assessment’s validity | 284 |
Section 121
Subsection 121(1)
Cases
Leo Beauchesne Inc. v. The Queen, 77 DTC 5308, [1977] CTC 398 (FCTD)
A discharge order based on a proposal made under Part III of the Bankruptcy Act discharged the taxpayer's liability relating to deductions which...
Section 172.1
Subsection 172.1(8)
Cases
Schnier v. Canada (Attorney General), 128 O.R. (3d) 537, 2016 ONCA 5
At the time of his bankruptcy, the taxpayer had unpaid income tax assessments of $4.478 million of which$4.424 million were under appeal to the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 223 - Subsection 223(1) | appealed assessment not an amount payable | 144 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(8) | assessed amount under appeal not an amount payable | 295 |
Section 173
Subsection 173(1)
Paragraph 173(1)(a)
Cases
In re Katari, 89 DTC 5324 (S.C.O.)
The taxpayer, who made an assignment in bankruptcy primarily as a result of his failure to make quarterly remittances of income tax instalments,...
Section 243
Cases
British Columbia v. Peakhill Capital Inc., 2024 BCCA 246
The Province appealed from an order pronounced in a receivership under the Bankruptcy and Insolvency Act (Canada) approving a reverse vesting...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | structuring a receiver’s sale of B.C. real property as a share sale to avoid LTT was not an avoidance transaction | 442 |