9 October 2025 APFF Roundtable, Q.2

Policy Tabs

Summaries

Summary Under

no penalty under s. 162(7) for failure to withhold or remit Pt. XIII tax on an s. 214(16)(a) deemed dividend

Interest accrued but was not paid by Canco during its 2024 taxation year on a loan from a non-resident corporation (NRco). Because such interest...

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Summary Under

no penalty under s. 227(9) for failure to withhold or remit Pt. XIII tax on a s. 214(16)(a) deemed dividend because time required to apply s. 18(4)

Interest accrued but was not paid by Canco during its 2024 taxation year on a loan from a non-resident corporation (NRco). Because such interest...

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Summary Under

interest accrued under s. 227(8.3)(b) between date of s. 214(16)(a) deemed dividend and remittance of Part XIII tax

Interest accrued but was not paid by Canco during its 2024 taxation year on a loan from a non-resident corporation (NRco). Because such interest...

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Summary Under

s. 227(9) inapplicable where no withholding (and also where there was no obligation to withhold pursuant to s. 227(8.5)(a)

Interest accrued but was not paid by Canco during its 2024 taxation year on a loan from a non-resident corporation (NRco). Because such interest...

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