Marie-Eve Gosselin, Paul Lynch, "A Review of Interest Deductibility Since Ludco", 2015 CTF Annual Conference paper

Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)

Purpose test not an anti-avoidance tool (p.7:10)

Novopharm can be seen as confirmation that the purpose test in subparagraph 20(l)(c)(i) cannot be...

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Summary Under
Tax Topics - Income Tax Act - Section 3.1

Withdrawal of draft s. 3.1 (p. 7:19)

[A] November 17, 2014 release from the Department of Finance stated…"All specific legislative proposals to...

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Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c)

CRA challenges to intercompany interest charges (p.7:18)

We have seen challenges [to the reasonableness of the interest rate] in related groups,...

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