Meaning of separate charge
13. A separate fee or charge for a financial service refers to an amount separate from the financial service. …[I]f for example,… a manufacturing company charged a fee for providing a loan to its customers, such a fee would be considered to be a separate fee or charge for a financial service
Partnerships included
15. …[A]mounts used to calculate a partnership's income under section 96 of the Income Tax Act for a particular taxation year should also be used to calculate the partnership's revenue amounts for purposes of the de minimis threshold tests.
Partnership interest revenues not excluded
22. Since the exclusion in subsection 149(4) applies only to interest or dividends received from a corporation related to the person, interest that a person receives from a partnership must, therefore, be included in calculating financial revenue.
Interest revenue from partner excluded
23. However, under subsection 126(3), a member of a partnership is deemed to be related to the partnership. Therefore, interest paid by a corporate partner to the partnership would be excluded from the calculation of a partnership's financial revenue, for the purposes of either de minimis threshold test.
Zero-rated precious metal sales included
25. If a refiner's revenue from zero‑rated supplies of precious metals were included in its financial revenue, the ratio of the refiner's financial revenue to total revenue could be relatively high, which could result in the refiner meeting the first de minimis threshold test. …
Secondary bond purchases generate good interest
35. However, if a person purchases bonds on the secondary market (that is, from a person other than the issuer of the bonds or an agent thereof), the person is not considered to have lent money to the bond issuer.
Cash generates bad interest
Example 3
… [I]nterest earned from [for example, a manufacturer's] bank accounts and Guaranteed Investment Certificates is considered to be interest with respect to making advances, lending money or granting credit and is included in the calculation of the de minimis threshold test under paragraph 149(1)(c).
