I-3, r. 1 - Regulation respecting the Taxation Act

Section 851.22.4r1 Disposition versions

2012-09-01

851.22.4R1. In this chapter,

“fixed payment obligation” of a taxpayer means a specified debt obligation under which

(a)  the amount and timing of each payment to be made by the debtor, other than a fee or similar payment or an amount payable because of a default by the debtor, were fixed when the taxpayer acquired the obligation and have not been changed; and

(b)  all payments are to be made in the same currency;

“primary currency” of a specified debt obligation means the currency with which the obligation is primarily connected or, if there is no such currency, Canadian currency;

“specified debt obligation” has the meaning assigned by the first paragraph of section 851.22.1 of the Act;

“tax basis” of a specified debt obligation at any time to a taxpayer has the meaning assigned by section 851.22.7 of the Act;

“total return” of a taxpayer from a fixed payment obligation means the amount, measured in the primary currency of the obligation, by which the total of all amounts each of which is the amount of a payment, other than a fee or similar payment, required to be made by the debtor under the obligation after its acquisition by the taxpayer, exceeds the cost to the taxpayer of the obligation.

O.C. 390-2012, s. 64.