debt

Summary Under
Tax Topics - Income Tax Act - Section 50 - Subsection 50(1)

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
Summary Under
Tax Topics - Income Tax Act - Section 39 - 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
Summary Under
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

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
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract
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) -- summary under Paragraph 20(1)(l)

Full Title
Gibraltar Mines Ltd. v. The Queen, 83 DTC 5294, [1983] CTC 261 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(l)
reserve for reimbursement entitlement

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) -- summary under Subsection 15(2)

Full Title
Tonolli Canada Ltd. v. Minister of National Revenue, 91 DTC 520, [1991] 1 CTC 2607 (TCC)
Summary Under
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2)

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

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 Investment Contract

Full Title
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

Delle Donne v. The Queen, 2015 TCC 150 -- summary under Investment Contract

Full Title
Delle Donne v. The Queen, 2015 TCC 150
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract
"debt" exists irrespective of demand

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

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

Full Title
Cloutier-Hunt v. The Queen, 2007 DTC 947, 2007 TCC 345 (Informal Procedure)
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract
no obligation until pay award

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

Fingold v. MNR, 92 DTC 2011, [1992] 2 CTC 2393 (TCC) -- summary under Investment Contract

Full Title
Fingold v. MNR, 92 DTC 2011, [1992] 2 CTC 2393 (TCC)
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract

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

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