Words and Phrases - "settle"

a
88
b
44
c
80
d
53
e
38
f
31
g
19
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
81
q
3
r
76
s
90
t
47
u
16
v
9
w
23
y
2

Matte v. The King, 2025 TCC 16

Summary Under
Tax Topics - Income Tax Act - Section 6 - Subsection 6(15)
the settlement of forgivable advances to an employee for less than the outstanding amounts produced s. 6(15) income

The taxpayer, who was employed as an investor advisor by a wealth management firm, had received over $1 million in interest-free loans (evidenced...

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Words and Phrases
settle
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract forgivable advances to employee were loans 151
Tax Topics - Income Tax Act - Section 248 - Subsection 248(26) deeming of taxpayer liability to be an obligation 82

7 October 2022 APFF Roundtable Q. 9, 2022-0942281C6 F - Section 80 - proposals under BIA

Summary Under
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a)
forgiveness under a Bankruptcy proposal occurred when it was court-approved

Pursuant to a proposal under the Bankruptcy and Insolvency Act, Opco and its creditor agreed to write off $600,000 of its $1 million debt and to...

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Words and Phrases
settle
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(13) s. 80(13) tax liability does not arise until the forgiveness 234

12 October 2016 Internal T.I. 2016-0637781I7 - Employee loan or debt extinguished or settled

Summary Under
Tax Topics - Income Tax Act - Section 6 - Subsection 6(15)
writing-off a statute-barred debt of an employee or remitting for financial hardship triggers benefit

An organization (apparently, a federal Crown corporation or agency) may “write off or remit” an employee debt based on employee financial...

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Words and Phrases
settle
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a) writing-off debt was its settlement 36

Wigmar Holdings Ltd. v. R., 97 DTC 5203, [1997] 2 CTC 263 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a)
legally binding settlement required for forgiveness, so that debt parking transaction and mortgage discharge did not discharge debt

The predecessor of the taxpayer ("Diversified Holdings") purchased, in an arm's length transaction, all the shares of another BC company ("860")....

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Words and Phrases
settle
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a) parking-lot (aka development) business of lossco continued after amalgamation with real estate developer notwithstanding two months between sale of parking lot and amalgamation 148

Carma Developers Ltd. v. The Queen, 96 DTC 1798, [1996] 3 CTC 2029 (TCC), briefly aff'd 96 DTC 6569 (FCA)

Summary Under
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a)

Under a plan that was approved by the requisite majority of creditors in accordance with the companies' Creditors Arrangement Act, various classes...

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Words and Phrases
extinguish settle novation

Richer v. The Queen, 2009 DTC 1413, 2009 TCC 394

Summary Under
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount
forgiveness at time of settlement agreement

A forgiven amount arose in respect of the indebtedness of the taxpayer for unpaid contribution amounts to a partnership at the time that he...

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Words and Phrases
settle