10 January 1992 Memorandum (Tax Window, No. 17, p. 14, ¶1773)

Expenses relating to a refinancing which do not involve borrowing money are not deductible pursuant to s. 20(1)(e). Generally, such expenses are eligible capital expenditures.

S.55(2) will apply where one wholly-owned subsidiary of a corporation transfers property to another wholly-owned subsidiary of that parent with unused capital losses ("Lossco"), with a view to Lossco immediately reselling the property at a capital gain.