Income Tax Folio S3-F1-C2 Deemed Interest Benefit on Shareholder Loans and Debts, April 10, 2025

Identification of loan or debt

• 2.9 Revolving credit, such as a line of credit or a credit card, is generally considered to be in the nature of a...

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Third-party interest payments not accommodated

• 2.14 The exception in s. 80.4(3)(a) does not apply if any party, other than the borrower, made or...

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Overview re s. 80.4(3)(c)

• 2.18 In general terms, the exception in paragraph 80.4(3)(c) applies for up to 15 years where an employee ownership...

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Continued accrual on non-forgiven portion

• 2.16 Where part of a loan is forgiven, s. 80.4(3)(b) does not obviate the requirement to compute the...

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Whether loan is received qua employee or qua shareholder

• 2.22 Factors that may indicate that a loan was received by a shareholder-employee from...

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S. 80.5 deduction potentially can be accessed by non-resident carrying on business in Canada

• 2.43 Where s. 80.4(2) results in a deemed interest...

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