13 January 1993 T.I. 922191 (November 1993 Access Letter, p. 500, ¶C76-077)

Where a loan is received by an employee of a corporation who owns all its shares, RC will consider that the loan was not contracted qua employee, except under exceptional circumstances.

There could be a taxable benefit where the corporation guarantees a bank loan made to an employee or a shareholder.

Where a corporation refunds to an employee the interest paid by him on a mortgage on his principal residence, that outlay will be deductible to the corporation where the usual conditions for deductibility are otherwise satisfied.

Where a loan is received by an employee of a corporation who owns all its shares, RC will consider that the loan was not contracted qua employee, except under exceptional circumstances.