An insolvent (but not bankrupt) company negotiates a settlement with CRA of unpaid source deductions and unremitted GST for less than the balance owing. Would this give rise to a forgiven amount or other income? After finding that the debt forgiveness rules would not apply, CRA stated:
Section 9… relates to income or loss from a business of property. If a settlement was reached with the CRA in relation to tax, then the difference in the amount would have to be returned to income. If however the settlement concerned the unremitted GST then this would be included in income pursuant to subsection 12(1)(x).