Newmont Canada Corporation v. Canada, 2012 DTC 5138 [at at 7292], 2012 FCA 214 -- summary under Paragraph 12(1)(c)

By services, 28 November, 2015

The taxpayer agreed to settle a loan owing to it of over $8 million plus accrued but unpaid interest through the payment to it by the debtor of $1 million. The settlement agreement provided that the $1 million repayment proceeds were to be "applied on account of the principal amount of the loan." This was enough to make out a prima facie case that the taxpayer did not receive payment of any of the unpaid interest. As the Minister had not provided evidence to contest this case, the taxpayer was entitled to a bad debt deduction in respect of the unpaid interest.

Topics and taglines
Tagline
allocation of all of debt settlement payment to principal rather than interest grounded a full bad debt claim for the "unpaid" interest
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
333712
Extra import data
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