Cases
Imperial Oil Ltd. v. Canada; Inco Ltd. v. Canada, 2006 DTC 6639, 2006 SCC 46, [2006] 2 S.C.R. 447
Before finding that the taxpayers were not entitled to recognize deductions under s. 20(1)(f)(ii) at the time they repaid U.S.-dollar denominated...
Administrative Policy
2014 Ruling 2013-0514191R3 - Debt restructuring, forgiveness and winding-up
underline;">: Currrent structure. Canco1 is obligated to its affiliate (Canco3) under non-interest-bearing U.S.-dollar debt evidenced by demand...
13 February 1996 External T.I. 9532285 - US DOLLAR CONVERTIBLE DEBENTURE
Respecting whether s. 51.1 would apply to the conversion of a U.S.-dollar denominated convertible debenture, CRA noted that under s. 51.1(c) the...
Articles
David W. Ross, "Convertible Debentures - Principal Amount", Resource Sector Taxation, (2006) Vol. IV, No. 2, p. 280.
Where a corporation issues a convertible debenture and the debenture is converted to shares, the amount paid-up for the shares that are issued is...