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

An offshore fund ("SLT"), in which the taxpayer had an interest, invested in instruments (labelled as "Notes") of non-resident subsidiaries of...

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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

After quoting (at para.55) the statement in Sattva that “While the surrounding circumstances are relied upon in the interpretive process, courts...

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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

Partly as a delayed consequence of CRA’s seizure of computers and dental equipment of a dental practice and the misplacing of records when his...

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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:

"Liability" v. "debt" (pp. 716-717)

The distinction so clearly made by Jackett P in Terra Nova Properties [67 DTC 5064] between liability for tax...

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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

Is the balance of the “future income tax liabilities” (being an accounting provision which was not deducted in computing income) presented in...

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Words and Phrases
debt

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

Anderson v. MNR, 92 DTC 2296 (TCC) (in which a letter of the taxpayer's accountant requesting the application of an allowable business investment...

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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

Respecting whether s. 39(2) applied on the payment of a previously declared dividend, CRA stated (TaxInterpretations translation):

A dividend, at...

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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

As a condition to distributing shares of Aco to the beneficiaries of a testamentary trust of which it was sole trustee, the trustee ("Pubco"),...

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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

Conditional sales contracts purchased by a corporation likely would qualify as "debt obligations," so that the corporation would qualify as a...

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Words and Phrases
debt

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

The "debt" need not be for the price of merchandise sold or services rendered in the course of business, but may also represent business expenses...

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Words and Phrases
debt

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

After a venture carried on through a U.S. subsidiary which was owned by the taxpayer and its Netherlands parent proved to be unsuccessful, the...

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Words and Phrases
debt

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

After the plaintiff discovered that his sale of a threshing machine to the defendant was legally ineffective, he received an award at trial for...

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Words and Phrases
debt

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

At the time of death of the deceased, a director of his family business corporation, he was under investigation by the Department of National...

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Words and Phrases
debt

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

The deceased had gone through the form of a marriage in Las Vegas while he had not yet completed his divorce with his first wife, and he soon had...

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Words and Phrases
debt

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

The appellant demolition company had a contractual obligation to pay the respondent construction company for a demolitions project (in exchange...

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Words and Phrases
debt

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

Interest awarded on a retroactive award of back pay by the Canadian Human Rights Tribunal did not represent interest on a "debt obligation" as...

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Words and Phrases
obligation debt

Delle Donne v. The Queen, 2015 TCC 150

In rejecting a submission that the taxpayer was not entitled to deduct a doubtful debt reserve for unpaid interest because no written demand to...

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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"

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

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

Before finding that payments made by a corporation to its shareholder-employees constituted debts of the employees rather than representing...

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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