CRA finds that an interest-free loan made outside a corporate group did not give rise to an imputed income benefit

CRA has found that the making of an interest-free loan by a Canadian corporation (owned by a discretionary trust) to another Canadian corporation (owned by the individual who was the sole trustee and a beneficiary of that trust) did not give rise to any taxable benefits.  CRA appears to accept the reasoning in Cooper that if there is no imputed interest under a specific provision such as s. 80.4, income should not be imputed under the more general conferral-of-benefit provisions.

Neal Armstrong.  Summaries of 12 December 2012 Memorandum 2012-0464411I7 under ss. 246(1) and 20(1)(e).