Words and Phrases - "repayment"
20 March 2017 External T.I. 2014-0545591E5 - Upstream Loan and Debt Forgiveness Rules
debt forgiveness not a repayment
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Words and Phrasesrepayment
|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||187|
|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||148|