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2018 Ruling 2018-0740931R3 F- deductibility of interest – convertible debentures-- summary under Subparagraph 20(1)(c)(i) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) interest on borrowed money used to pay a premium on the cash redemption of convertible debentures is deductible Proposed transactions ACo, a listed Canadian public company, whose outstanding convertible debentures (the “Debentures”) are about to mature, will borrow from a lender (BCo) under “Loan 3.” ... However, upon receiving the notices of redemption for the Debentures, ACo will have the right to redeem such Debentures for an amount corresponding to the market value of the ACo shares into which they are convertible – which it will do, using proceeds of Loan 3 and thereby paying a “Conversion Premium C” over the redeemed Debentures’ principal amount. ...

10 November 2020 External T.I. 2020-0861461E5- TI – Tax Treatment of Loan Forgiveness under CEBA-- summary under Subparagraph 12(1)(x)(iv) Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(1)- Paragraph 12(1)(x)- Subparagraph 12(1)(x)(iv) the forgivable loan portion of a CEBA loan is a s. 12(1)(x)(iv) receipt The Canada Emergency Business Account (“CEBA”) provides interest-free loans of up to $40,000 to small businesses and not-for-profit organizations to fund their expenses. ... This is also the case where the taxpayer made a subsection 12(2.2) election to reduce the paragraph 12(1)(x) inclusion in the year of receipt. … ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Gross Revenue Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Gross Revenue Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

19 May 1994 External T.I. 9405515- GROSS REVENUE & RECAPTURED DEPRECIATION-- summary under Subsection 402(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3) Recapture of depreciation does not constitute "gross revenue" for purposes of Regulation 402(3). ...

3 October 1996 External T.I. 9631565- FEES FOR RRSP & RPP-- summary under Subsection 146(5) Summary Under Tax Topics- Income Tax Act- Section 146- Subsection 146(5) The payment of administration or management fees by an annuitant will constitute the payment of a premium to the RRSP. ...

1993 External T.I. 9335545 F- Sub — 256(2) and T2144-- summary under Subsection 256(2) Summary Under Tax Topics- Income Tax Act- Section 256- Subsection 256(2) Re RC's requirements for acceptance of a late-filed Form T2144. ...

16 August 1995 External T.I. 9512405- VESSELS- PARTIAL DISPOSITION & 13(16) ELECTION-- summary under Subsection 13(16) Summary Under Tax Topics- Income Tax Act- Section 13- Subsection 13(16) A partial disposition of a vessel will qualify as a disposition of a vessel for purposes of s. 13(16). ...

TREATY & LIFE INSURANCE PROCEEDS-- summary under Article 13 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 13 The word "gains" in article XIII of the Canada-U.S. ...

9 January 1996 Ministerial Correspondence 952924A- CASH CONCENTRATION ACCOUNTS & PART I.3-- summary under Subsection 181.2(4) Summary Under Tax Topics- Income Tax Act- Section 181.2- Subsection 181.2(4) Inconclusive discussion of group concentration accounts. ...

2004 Ruling 2004-0099651R3- Migration to Canada / PUC Reduction-- summary under Subsection 2(1) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(1) Opinion that a non-resident corporation would become resident in Canada upon replacing its board with a new board a majority of whom resided in Canada and which conducted meetings in Canada. ...