Cancellation of debt a key element of most restructurings generally triggers taxable income. The German tax authorities had issued an administrative decree (the "Tax Restructuring Decree" - Sanierungserlass), however, declaring that, upon the satisfaction of certain requirements and conditioned on forfeiture of any loss carry forwards, the cancellation of debt income ("CODI") would not be taxed.
Proposed appeal fails to raise broader issues about the intersection of copyright and insolvency law
Canada, Ontario, Copyrights, Insolvency & Restructuring, Litigation, Borden Ladner Gervais LLP, Copyright infringement, Court of Appeal for Ontario