Taxation of Corporate Finance provides a detailed description of the Canadian federal income tax regime applicable to shares, corporate debt, and related financial instruments. It covers taxation of shares and debt of Canadian corporations and foreign corporations, the specific regime governing mark-to-market property, and specified debt obligations held by financial institutions, securities loans, and repurchase agreements and derivatives.

This looseleaf also explains general concepts such as distinguishing assets and liabilities held on income and capital accounts and determining whether a particular financial instrument is a debt, equity, or something else.

Highlights of the first volume

Chapter 1, Basic Concepts — New CRA Views and commentary have been added regarding proposed character conversion rules that attempt to provide statutory bifurcation rules and election under subsection 39(4) of the Act
Chapter 2, Treatment of Debt Held by Taxable Holders Resident in Canada — Commentary and a CRA View have been added for topics like where free rent was provided “in satisfaction of” interest, doubtful debts and bad debts, general dispositions, seizure of property by a creditor, and loss from disposition of a debt
Chapter 3, Treatment of Debt Held by Non-Residents and Tax-Exempts and Treatment of Guarantees — Commentary and case law have been updated with new CRA Views regarding participating debt interest, fully exempt interest, treatment of dispositions, withholding tax considerations, considerations for tax-exempts for qualified investments, and prohibited investments
Chapter 4, Debt: Treatment of the Issuer — Commentary, case law, and CRA Views have been added regarding thin-capitalization rules, other financing costs, debt forgiveness rules, and documentation requirements

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Taxation of Corporate Finance

Taxation of Corporate Finance