Words and Phrases - "interest"

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13 August 2004 Internal T.I. 2004-0076861I7 F - Investissement à l'étranger

return payable on maturity that was not expressed as a percentage or fraction qualified as interest

A resident individual (the taxpayer) lent a sum to a Barbados borrower pursuant to a debenture contract which provided that the return was payable...

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Words and Phrases
interest
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) s. 75(2) would apply where loan proceeds would ultimately revert to the taxpayer 74
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(2) - Paragraph 108(2)(a) suspension of redemption right for more than one year would disqualify as s. 108(2)(a) trust 131

18 May 2006 Internal T.I. 2005-0162821I7 F - Imposition - article 1619 du Code civil

additional indemnity awarded under CCQ Art. 1619, computed by applying an interest rate to damages award, was interest

The Corporation commenced an action against the Insurer (which had refused to pay insurance proceeds on the death of the life of the Insured...

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Words and Phrases
interest

Agence du revenu du Québec v. Bernardin, 2021 QCCA 625

interest that arose prior to a class action judgment becoming res judicata was non-taxable – interest arising thereafter was taxable even though judgment not yet quantified

An individual, by virtue of being part of a group of class action claimants, was awarded damages in 2004 of $1,200 for each of the eight winter...

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Words and Phrases
interest

7 October 2011 Roundtable, 2011-0412161C6 F - Timing of the increase in interest - stock option

grant of in-the-money options to key employee as part of same series could be a significant increase in interest – which otherwise occurs on exercise

Mr. X implemented an estate freeze in favour of his children and a holding corporation respecting his wholly-owned operating corporation, which he...

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Words and Phrases
interest

12 December 2018 Interpretation Letter of the CRA Charities Directorate to Simon Cheung File GC 341217

debt is an "interest in a corporation, other than shares”

The Charities Directorate stated the following respecting a proposal to eliminate a foundation's positive divestment obligation percentage arising...

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Words and Phrases
interest

Plains Midstream Canada ULC v. Canada, 2019 FCA 57

As part of a complex set of transactions, a predecessor of the taxpayer agreed to assume a $225M loan that was due in perhaps 43-years’ time and...

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Words and Phrases
interest
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 16 - Subsection 16(1) s. 16(1) can only apply to a debtor if it equally applies to the creditor 398

Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONCA 727

additional discount fee, but not admin fee, was interest rather than fee

A typical loan made by the lender (ClearFlow) to the borrower bore base interest rate of 12% p.a. compounded monthly, an administration fee that...

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Words and Phrases
fee interest
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) daily discount fee had the 3 attributes of interest 381

Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONSC 7286, rev'd 2018 ONCA 727

The typical loan agreement for a loan (a “Loan”) by the respondent (“ClearFlow”) to the applicant (“SPN”) provided for a base interest...

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Words and Phrases
interest

Joint Committee, "Small Business Deduction Rules under Section 125 of the Income Tax Act - Follow-Up to Our Meeting with Canada Revenue Agency", 2 June 2017 Joint Committee Submission to Finance respecting the Small Business Deduction, appending Submission to Randy Hewlett of the Income Tax Rulings Directorate dated 14 February 2017

Issues with cooperatives (p. 2)

Every farming or fishing Canadian-controlled private corporation (“CCPC”) selling substantially all of its...

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R. v. Melford Developments Inc., 82 DTC 6281, [1982] CTC 330, [1982] 2 S.C.R. 504

In the absence of this provision, "interest" in Part XIII would refer primarily to "the payment of rent by a borrower for the use of the principal...

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Words and Phrases
interest
Locations of other summaries Wordcount
Tax Topics - Treaties - Income Tax Conventions 59
Tax Topics - Treaties - Income Tax Conventions - Article 11 guarantee fees were not interest 82

Bennett and White v. The King, 49 DTC 514, [1949] CTC 1, [1949] S.C.R. 287

In finding that annual amounts described in various resolutions of the taxpayer as "interest" in fact were guarantee payments, Locke J. stated (p....

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Words and Phrases
interest

Reference as to the Validity of Section 6 of the Farm Security Act, 1944 of Saskatchewan, [1947] S.C.R. 394, aff'd [1949] AC 110

Section 6 of the Farm Security Act 1944 (Saskatchewan) provided that in the event of a crop failure, the principal of a mortgage on a farm would...

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Words and Phrases
interest

Morscher v. MNR, 92 DTC 2214, [1992] 2 CTC 2534 (TCC)

The taxpayer, who carried on a commercial litigation practice in partnership with another lawyer, was denied the deduction of interest which...

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Words and Phrases
interest

Pike v. Revenue and Customs Commissioners, [2014] BTC 33, [2014] EWCA Civ 824

The taxpayer subscribed for loan stock of a family company at a price equal to its principal amount. Although the loan stock did not bear any...

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Words and Phrases
interest