Words and Phrases - "repayment"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
72
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
89
t
46
u
15
v
9
w
22
y
2

20 March 2017 External T.I. 2014-0545591E5 - Upstream Loan and Debt Forgiveness Rules

Summary Under
Tax Topics - Income Tax Act - Section 90 - Subsection 90(14)
debt forgiveness not a repayment

When an upstream loan to Canco from its wholly owned CFA is forgiven following a sale of the CFA, this will not qualify as a repayment of the loan...

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Words and Phrases
repayment
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 90 - Subsection 90(9) potential indefinite application of surplus where upstream loan forgiven after FA sale 203
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Excluded Obligation - Paragraph (a) s. 80 non-application where s. 90(6) applies to forgiven loan even if offsetting surplus deduction 156