Debt Forgiveness

Understand how the debt forgiveness rules work, how forgiven amounts are calculated, and how to apply reductions in the correct order.

Michael Cadesky explains section 80 in practical terms so CPAs can recognize commercial obligations, avoid common traps, and apply the rules accurately.

On-Demand
On-Demand

2 Hours CPD
2 Hours CPD

Included in Archive
Included in Archive

Course Overview

The debt forgiveness rules are among the most technical provisions in the Act. When a commercial debt is settled or deemed to be settled, a forgiven amount may arise, which can reduce tax attributes or, in some cases, be included in income. Although the rules are designed to be fair, the material demonstrates that they are intricate, prone to calculation errors, and contain many exceptions and adjustments that must be applied in the correct sequence.

This course provides a straightforward explanation of how the debt forgiveness rules work in practice. You will learn what counts as a commercial obligation, how the forgiven amount is calculated, and which debts are excluded. The program highlights common traps such as trust and inheritance transfers that can unexpectedly trigger a settlement, then walks through the required order for applying forgiven amounts to tax attributes and the options for reducing UCC, resource pools, and ACB. Also covered: Settlements, deemed settlements, debt parking, and the main relief provisions available to insolvent taxpayers and certain individuals, trusts, and non-residents.
Learning Objectives
1
Understand when the debt forgiveness rules apply and how a forgiven amount is determined
2
Recognize which debts are excluded from section 80
3
Identify situations that can unexpectedly trigger a settlement or deemed settlement
4
Become familiar with the key relief provisions available to insolvent taxpayers

Seminar Snapshot

Date Recorded
OCTOBER 27, 2020
Presentation
Yes
Slides
Yes
Detailed Notes
No
Technical Corner
No
Teach Test
No
Resources
No
Included in Archive
Yes

DEBT FORGIVENESS

Duration
1 hour with Q&A Recording
CPD CPD Certificate
Category
Special Topics
Debt Forgiveness builds on the core concepts by showing how forgiven amounts affect a taxpayer’s existing tax attributes. The course explains the required order for applying reductions, beginning with various loss balances and then moving to optional adjustments of UCC, resource pools, and adjusted cost base. Participants learn how these reductions interact with different types of assets and how to approach situations where the taxpayer has limited attributes available to absorb the forgiven amount.

The session also covers how forgiven amounts can be managed after reductions have been applied, including when they may be transferred to a related corporation and when they must be included in income. The material provides a clear explanation of how settlement and deemed settlement rules operate, including shares-for-debt scenarios, debt substitutions, statute-barred debts, and debt parking. Relief measures are explained in a practical way, including insolvency deductions and reserves available to corporations, trusts, individuals, and non-residents carrying on business in Canada. The focus is on helping CPAs understand how to apply section 80 in real situations and avoid common errors.


After completing this program, you will be confident with:
  • Determining whether a debt is a commercial obligation for section 80 purposes
  • Identifying trust and inheritance situations that may trigger unexpected settlements
  • Applying reductions to losses, UCC, resource pools, and ACB correctly
  • Understanding when forgiven amounts must be included in income or may be transferred
  • Recognizing how settlement, deemed settlement, and debt parking rules operate
This course is essential if you are responsible for:
  • Advising clients involved in debt settlements, restructurings, or reorganizations
  • Reviewing related-party loans, trust notes, or estate transfers
  • Preparing corporate tax returns where loss balances or tax attributes may be affected by section 80
  • Identifying settlement or deemed settlement scenarios in amalgamations, wind-ups, or share exchanges
  • Working with clients facing liquidity issues or insolvency where relief provisions may apply

Meet Your Presenter

Michael Cadesky

Michael Cadesky

FCPA, FCA, FTIHK, CTA, TEP (EMERITUS)

Michael Cadesky is the managing partner at Cadesky Tax and a committed contributor to the tax and accounting professions since 1980, earning the title of Fellow from CPA Ontario. He is a past governor of the Canadian Tax Foundation, past chair of STEP Canada and STEP Worldwide, and past chair of the CPA Canada Tax Committee for Small and Medium-Sized Enterprises. Michael is also the co-author of 11 books on tax subjects and the author or co-author of numerous papers and articles on Canadian and international taxation.

Frequently Asked Questions
Once you complete your purchase, you will create your account if you haven't already. You can access the course anytime through our platform. All Cadesky Tax Seminars programs come with one-year access.
Yes. This course is eligible for verifiable CPD hours for Canadian CPAs. A downloadable Certificate of Completion will be available once you complete all required modules.
Our programs are designed for CPAs and tax professionals who want to deepen their technical expertise. While no prerequisites are required, a working knowledge of Canadian tax will help you get the most out of the material.
On-demand courses include the full video presentation, downloadable slides, and additional resources mentioned in the Seminar Snapshot (Technical Corner, teach test, checklists).
Yes. You will have unlimited access to the course materials within the 1-year access period, so you can revisit the content anytime to refresh your knowledge.

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