Words and Phrases - "indebtedness"

a
89
b
44
c
86
d
56
e
43
f
31
g
20
h
15
i
77
j
2
k
2
l
32
m
57
n
29
o
40
p
82
q
3
r
78
s
95
t
47
u
16
v
10
w
23
y
2

11 May 2005 Roundtable, 2005-0118731C6 F - Contrat avec une société d'affacturage

Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(f)
characterization as “loans and advances” and “all other indebtedness” based on legal character

A factoring company advances sums to Corporation A at a discount to the face value of the discounted receivables, and then applies the amounts...

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Words and Phrases
loan advance indebtedness

4 February 2015 External T.I. 2015-0565741E5 - Canadian-controlled private corporation

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract
indemnity agreement was not "indebtedness"

Before finding that an indemnity agreement was not "indebtedness," CRA discussed authorities on "indebtedness" including Fingold, Beament and

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Words and Phrases
indebtedness
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) s. 256(5)(b) applied to acquisition right upon default under indemnity 167
Tax Topics - Income Tax Act - Section 256 - Subsection 256(6) s. 256(6) does not protect a company's CCPC status where its shares are pledged to a pubco to secure an indemnity, not debt 235

Barejo Holdings ULC v. The Queen, 2015 DTC 1216 [at at 1405], 2015 TCC 274, aff'd on other grounds 2016 FCA 304

Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract
"notes" which tracked actively-managed reference pool of assets were "debt"

The question referred by the parties pursuant to Rule 58 was whether two contracts, entitled Notes and issued for US $998 million by affiliates of...

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Words and Phrases
debt indebtedness
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) "notes" which tracked actively-managed reference pool of assets were "debt" and "indebtedness" 184
Tax Topics - Income Tax Act - Section 95 - Subsection 95(1) - Investment Property "notes" which tracked actively-managed reference pool of assets were "debt" and "indebtedness" 184
Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 quaere whether there is a federal law of "debt" or "charity" 334