Words and Phrases - "repayment"

66
29
47
37
28
22
12
10
52
1
2
19
38
20
29
62
1
51
59
35
8
7
11
1

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

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 for purposes of the upstream loan rules so that, at best, reserves will need to be claimed under s. 90(9) throughout the indefinite lifetime of Canco.

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 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