Tax treatment and consequences of debt restructuring and workouts : Canada

This comparative survey provides a comprehensive overview of the tax consequences of debt restructuring and workouts, consisting in alterations (incentives) of an existing indebtedness through, among others, (i) reduction of principal amount, (ii) deferral (of interest and/or principal redemption payments) or extension of maturity date, (iii) adjustments in interest rate (both downwards - as an incentive - and upwards as the flip side of an incentive), (iv) waiver of remedies, (v) addition of co-obligor, (vi) addition of guarantor or collateral, (vii) addition of warrants or equity kickers to the debt, (viii) change of debt to a recourse debt, (ix) conversion into equity and (x) waiver of debt or declaration of subordination in combination with a clause of reinstatement upon return to a financially sound position (also in the form of reinstatable debt certificates), and increase in interest rates.