Words and Phrases - "debt"

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Barejo Holdings ULC v. Canada, 2020 FCA 47

the amount payable under a “debt” for s. 94.1(1)(a) purposes need not be crystallized until maturity
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Words and Phrases
debt liability
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Consistency presumption of consistent expression is not absolute 252
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract 3 tests for what constituted debt under s. 94.1(1)(a) 300

Moose Factory Restaurant Properties Ltd. v. The Queen, 2019 TCC 156

debt is obligation to pay a sum certain or amount reducible to sum certain
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Words and Phrases
debt
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) arrangements were not structured to give rise to a debt 358

Hokhold v. Canada, 2018 FCA 163

bad debt claim requires the specific identification of which “debt” claims went bad
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Words and Phrases
debt

Colin Campbell, "Liability for the Tax on SIFT Partnerships: A Rejoinder", 2011 Canadian Tax Journal, Vol 59, p. 709:

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Words and Phrases
liability debt
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) 39

28 January 2016 External T.I. 2015-0617771E5 F - Bump calculation

future income tax liabilities not treated as obligations to pay an amount
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Words and Phrases
debt

6 April 1993 T.I. (Tax Window, No. 30, p. 5, ¶2493)

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Words and Phrases
debt

5 November 2013 External T.I. 2013-0501241E5 F - Application of subsection 39(2)

declared dividend is a debt to which s. 39(2) applies
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Words and Phrases
debt

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

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
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Words and Phrases
debt
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract indemnity agreement was not "indebtedness" 47
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

24 March 2005 Internal T.I. 2005-0115921I7 - Specified debt obligations & loan originating cost

debt definition - includes conditional sales contracts
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Words and Phrases
debt

Gibraltar Mines Ltd. v. The Queen, 83 DTC 5294, [1983] CTC 261 (FCA)

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Words and Phrases
debt

Tonolli Canada Ltd. v. Minister of National Revenue, 91 DTC 520, [1991] 1 CTC 2607 (TCC)

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Words and Phrases
debt

Lyall & Sons Construction Co. v. Baker, [1933] 2 DLR 264 (Ont CA)

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Words and Phrases
debt

Cloutier-Hunt v. The Queen, 2007 DTC 947, 2007 TCC 345 (Informal Procedure)

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Words and Phrases
obligation debt

Delle Donne v. The Queen, 2015 TCC 150

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Words and Phrases
debt
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) reserve could be claimed on appeal 90
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(l) doubtful debt reserve claimed implicitly as at the year end in light of subsequently revealed information 542
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) bad debt deduction taken as at Dec. 31 in light of information available at April 30, and could be claimed implicitly or on appeal 478

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

"notes" which tracked actively-managed reference pool of assets were "debt"
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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

Fingold v. MNR, 92 DTC 2011, [1992] 2 CTC 2393 (TCC)

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Words and Phrases
debt
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(1) 69

Noble v. Lashbrook, 40 DLR 93, [1918] 1 WWR 918 (Sask CA)

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Words and Phrases
debt

Guay Estate v. The Queen, 75 DTC 5090 (FCTD)

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Words and Phrases
debt

Walsh Estate v. Minister of Finance (B.C.), [1979] CTC 251, at 257 (BCSC)

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Words and Phrases
debt