Do ss. 53(1)(f.1) and 80.01(8) apply simultaneously when Corporation "X" disposes of its debt of a wholly-owned corporation to another taxable Canadian corporation (“Corporation "Y") with which it is related only because of s. 251(5)(b)? After indicating that the capital loss denied by s. 40(2)(e.1) is added by s. 53(1)(f.1) to the ACB of the debt “immediately after the acquisition of the debt,” CRA stated (TI translation):
[T]aking subsections 80.01(6) and (7) into account, the debt becomes a parked obligation at the time of its acquisition by Corporation "Y" and, therefore, the ACB of the debt to the holder should be established precisely at that moment. Since this determination is made at a time that precedes the adjustment provided for under paragraph 53(1)(f.1), it could be ["se pourrait"] that this deeming rule in paragraph 80.01(8) results, under these circumstances, in a forgiven amount that is subject to the application of section 80.