Subsection 61.3(1)
Administrative Policy
2 December 2025 CTF Roundtable, Q.1
In Year 1, a corporation resident in Canada ("Parentco") made a $1,000 interest-free loan to its wholly owned Canadian subsidiary ("Subco") and,...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | abuse to generate two losses out of the same investment | 298 |
19 March 2003 External T.I. 2002-0171825 F - DEDUCTION POUR INSOLVABILITE LIQUIDATION
A corporation with no assets and a debt owing to its sole shareholder as its only liability has that debt forgiven (resulting in an income...
Paragraph 61.3(1)(b)
Administrative Policy
7 November 2001 External T.I. 2001-0103805 F - SENS D'ACTIFS
A corporation in financial difficulty that no longer has any tangible property but has a balance of non-capital losses and undeducted scientific...
Words and Phrases
assetSubsection 61.3(3) - Anti-avoidance
Administrative Policy
19 December 2013 External T.I. 2012-0468851E5 F - Deduction for Insolvency
Mco has a wholly-owned subsidiary (Aco) which is in financial difficulty, is not an insurance corporation, bank or credit union, does not have any...