CRA rules on a hurried (under one month) loss shift

CRA ruled on loss-shifting transactions which were to be reversed (on a cashless basis) less than a month after being implemented. This likely implies that the intragroup loan amounts were quite large – which is consistent with the unusual absence of a representation that the loans amounts were something which could have been borrowed from a bank.

In order to avoid a daylight loan, the various amounts were split up into bite-sized chunks, with the money being circled.

Neal Armstrong. Summary of 2014 Ruling 2014-0525441R3 under s. 111(1)(a).