Words and Phrases - "exercisable"
26 May 2016 Internal T.I. 2016-0628741I7 - Interaction of s. 80 and s. 143.4
right to reduce notwithstanding that conditions precedent to interest forgiveness not yet satisfied
The Taxpayer, which for a number of years had gone without paying interest on its Notes, had a Plan accepted in Year X and implemented in Year X+1...
Words and Phrases
exercisableLocations of other summaries | Wordcount | |
---|---|---|
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a) | no settlement of debt under Plan before conditions precedent fulfilled | 162 |
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest only deductible in the year paid or payable | 163 |
Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(4) | s. 143.4(4) caused an immediate income inclusion of prior years’ interest that was to be forgiven at a later date under an approved Plan of Compromise | 185 |