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Creditors Tax Court

Rivkin Radler LLP

Writing Off A Loan – Simultaneous COD Income and Bad Debt Deduction? Not Necessarily

Rivkin Radler LLP on

If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related...more

Rivkin Radler LLP

Intercompany Loan Treated As Constructive Distribution and Contribution

Rivkin Radler LLP on

Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...more

Rivkin Radler LLP

Debt or Equity? The Never-Ending Question For Closely Held Businesses

Rivkin Radler LLP on

What Was Intended? Transactions between commonly controlled, closely held businesses are often conducted in an informal manner. This is unfortunate because, in the absence of documentation, it is sometimes difficult to...more

Bennett Jones LLP

Secured Creditors Can Appeal to Tax Court on Behalf of a Bankrupt

Bennett Jones LLP on

The Tax Court of Canada recently confirmed in International Hi-Tech Industries Inc v The Queen, 2014 TCC 198, that in certain circumstances a secured creditor can commence or continue a tax appeal on behalf of a bankrupt...more

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