FAPI and Debt Forgiveness - Now You See It, Now You Don't

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FAPI and Debt Forgiveness - Now You See It, Now You Don't

Author(s): Nitikman, Joel

Date: March 24 2005

Suppose a taxpayer in Canada owns all of the shares of a foreign corporation ("CFA1") which in turn owns all the shares of another foreign corporation ("CFA2"). CFA2 lends money to CFA1. At some later time CFA2 is wound up into CFA1 and, as a result, the debt is forgiven. What, if any, are the tax consequences to CFA1 of the debt forgiveness?

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