Amanda S.A. Doucette, Britney Wangler, "Normal Borrowing by CCPC Owners Can Create an Income Inclusion", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 1

Summary Under
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.17)

Potential application of s. 15(2.17) where corporation guarantees loan to individual shareholder (p. 1)

[T]he back-to-back loan rules…may have...

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Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Specified Right

A secured guarantee by a private corporation of a bank loan to its individual shareholder may very well cause an income inclusion to the...

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