24 March 2005 Internal T.I. 2005-0115921I7 - Specified debt obligations & loan originating cost -- summary under Investment Contract

Conditional sales contracts purchased by a corporation likely would qualify as "debt obligations," so that the corporation would qualify as a restricted financial institution, i.e., a corporation whose principal business was the purchasing of debt obligations issued by arm's length persons. Before quoting Beament Estate v. MNR CRA stated:

According to Creditor-Debtor Law in Canada, Dunlop 2nd Ed. 1995, there is no all-encompassing definition of "debt" and defining this term or the term "debt obligation" is not an easy task. While the text states that the meaning of the word "debt" is changing over time, the most commonly accepted meaning of the word "debt" is to describe an obligation to pay a sum certain or readily reducible to certainty.

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