Words and Phrases - "indebtedness"
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...
4 February 2015 External T.I. 2015-0565741E5 - Canadian-controlled private corporation
indemnity agreement was not "indebtedness"
Before finding that an indemnity agreement was not "indebtedness," CRA discussed authorities on "indebtedness" including Fingold, Beament and
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
"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...
| 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 |