Words and Phrases - "settle"
7 October 2022 APFF Roundtable Q. 9, 2022-0942281C6 F - Section 80 - proposals under BIA
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...
Words and Phrases
settleLocations of other summaries | Wordcount | |
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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
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...
Words and Phrases
settleLocations of other summaries | Wordcount | |
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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)
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")....
Words and Phrases
settleLocations of other summaries | Wordcount | |
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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)
Under a plan that was approved by the requisite majority of creditors in accordance with the companies' Creditors Arrangement Act, various classes...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | 157 |