(1.1)-(9)

Subsection 15(1.1) - Conferring of benefit

Cases

Wong v. The Queen, 99 DTC 458 (TCC)

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Tax Topics - General Concepts - Purpose/Intention 198

Canada v. Wu, 98 DTC 6004 (FCA)

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Tax Topics - General Concepts - Purpose/Intention 73

Administrative Policy

2015 Ruling 2015-0604051R3 - Internal Reorganization

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(iii) note resulting from share redemption required to be vapourized on amalgamation/GAAR assessment required to reduce outside Canadian basis that US parents “paid for” by paying 5% Canadian withholding tax/rep re pubco share value being unaffected 815
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1.11) s. 55(3)(a) rulings conditional on U.S. parents accepting GAAR assessments to reduce their outside basis 224
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(2) extensive reps required re series of transactions 45

10 October 2014 APFF Roundtable Q. 19, 2014-0538041C6 F - 2014 APFF Roundtable, Q. 19 - Stock dividend

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) SI apportionment to stock dividend prefs 245
Tax Topics - Income Tax Act - Section 74.4 - Subsection 74.4(2) non-application to stock dividend, cf. s. 86 reorg 243
Tax Topics - Income Tax Regulations - Regulation 6205 - Subsection 6205(2) purpose test in Reg. 6205(2)(a) is not necessarily accomplished by all estate freezes/"arrangement" broad 403

26 November 2013 CTF Roundtable, 2013-0507981C6 - Stock dividend by a foreign corporation 15(1.1)

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9 May 1990 Meeting (October 1990 Access Letter, ¶1474)

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Subsection 15(1.2)

Articles

Mark Coleman, Daniel A. Bellefontaine, "Forgiveness, Foreign Affiliates and FAPI: a Framework", Resource Sector Taxation (Federated Press), Vol. X, No. 1, 2015, p.694

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Subsection 15(1.4) - Interpretation — subsection (1)

Paragraph 15(1.4)(c)

Administrative Policy

6 December 2016 External T.I. 2016-0666841E5 F - Sale of property for POD less than FMV

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) s. 246(1) applicable to indirect shareholder benefit if direct shareholder influenced the benefit conferral 193
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) potential application to immediate shareholder re benefit on indirect shareholder 199

24 June 2015 External T.I. 2015-0575911E5 F - Benefit to shareholder or conferred on a person

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Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) benefit conferred on spouse of individual shareholder of parent 137
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) benefit conferred on spouse of individual shareholder of parent 235

3 March 2015 Internal T.I. 2014-0527841I7 F - Avantage imposable pour aéronef

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(c) apportionment of aircraft use between business and personal 66
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) benefits from personal use of corporate aircraft based on the cost of similar benefit from arm's length supplier 168
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) s. 15(1.4)(c) applied to extend scope of Massicotte indirect benefit doctrine 781

10 October 2014 APFF Roundtable, 2014-0538101C6 F - Avantage automobile en vertu de 15(5)

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Subsection 15(2) - Shareholder debt

Cases

Canada v. Gillette Canada Inc., 2003 DTC 5078, 2003 FCA 22

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Magicuts Inc. v. Canada, 2001 DTC 5665, 2001 FCA 332

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss trade receivable contributed on capital account to sub 66

Wallace v. Canada, 98 DTC 6326 (FCA)

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Dunlop v. The Queen, 95 DTC 5351 (FCTD)

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The Queen v. Silden, 93 DTC 5362 (FCA)

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Nellis v. The Queen, 86 DTC 6377, [1986] 2 CTC 216 (FCTD)

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Tax Topics - Income Tax Act - Section 76 45

Schlamp v. The Queen, 82 DTC 6274, [1982] CTC 304 (FCTD)

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See Also

St-Pierre v. The Queen, 2017 CCI 69

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Estoppel limited estoppel remedies in Quebec/no abusive conduct by CRA 439
Tax Topics - General Concepts - Unjust Enrichment taxpayer was unjustly enriched when he received capital dividends that subsequently were declared to not have been validly paid as dividends 81

Erb v. The Queen, 2000 DTC 1401 (TCC)

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Lemoine v. The Queen, 96 DTC 1655 (TCC)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Illegality prohibited loan recognized 29

Haynes v. The Queen, 94 DTC 1906 (TCC)

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285614 Alberta Ltd. and Maplesden v. Burnet, Duckworth & Palmer, [1993] WWR 374, 8 BLR (2d) 280 (Alta. Q.B.)

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Tax Topics - General Concepts - Negligence and Fiduciary Duty failure to advise that opinion might be incorrect 155

Laflamme v. MNR, 93 DTC 50 (TCC)

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Tonolli Canada Ltd. v. MNR, 91 DTC 520 (TCC)

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Words and Phrases
debt

Wolinsky v. MNR, 90 DTC 1854 (TCC)

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Miconi v. MNR, 85 DTC 696 (TCC)

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Heal v. MNR, 80 DTC 1169 (TCC)

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Administrative Policy

2 October 2014 External T.I. 2013-0506551E5 - Transitioning from 15(2) to a PLOI

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.11) PLOI election unavailable for pre-2012 loan that is repaid and relent/ s. 15(2) applies only to 1st loan 202

27 February 2014 External T.I. 2013-0506401E5 - Loan from a partnership to an individual

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) bona fide loan not a transfer 135

2010 Ruling 2010-0353141R3 - Related Foreign Entity Financing

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17 February 1997 T.I. 964065

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25 November 1993 Memorandum 932357 (C.T.O. "Interest Cost on Bridge Financing upon Relocation")

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5 January 1993 T.I. 923226 (November 1993 Access Letter, p. 491, ¶C9-290; (Tax Window, No. 28, p. 16, ¶2375)

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92 C.R. - Q.43

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19 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 19, ¶1050)

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October 1989 Revenue Canada Round Table - Q3 (Jan. 90 Access Letter, ¶1075)

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84 C.R. - Q.16

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80 C.R. - Q.39

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80 C.R. - Q.7

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IT-119R4 "Debts of Shareholders and Certain Persons Connected with Shareholders"

Articles

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33

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Randy S. Morphy, "The Modern Approach to Statutory Interpretation, Applied to the Section 15 Anomaly in Foreign Affiliate Financing", Canadian Tax Journal, (2013) 61:2, 367-85: summary under s. 15(2.3).

Chris Van Loan, "Canada Revenue Agency Rules Positively on Second Tier Financing Structure", Business Vehicles, Vol. XIII, No. 4, 2010, p. 713.

Singer, "Shareholder Loan Can Be Used to Acquire Recreational Home Outside of Canada", Taxation of Executive Compensation and Retirement, December 1990/January 1991, p. 381.

"Loan May Be Disqualified Where it is Made to Acquire Dwelling Already Occupied as Owner", Taxation of Executive Compensation and Retirement, March 1990, p. 249.

Subsection 15(2.11) - Pertinent loan or indebtedness

Administrative Policy

7 November 2014 External T.I. 2014-0542061E5 - Section 15(2.12), follow up to 2014-051943

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Tax Topics - Income Tax Act - Section 227 - Subsection 227(6) inability to refund Part XIII tax which disappears on late PLOI election if non-timely application 159

2 October 2014 External T.I. 2013-0506551E5 - Transitioning from 15(2) to a PLOI

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) s. 15(2) applies only to 1st loan 0

8 September 2014 External T.I. 2013-0482991E5 - 15(2) and related provisions

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) assignment of debt not its repayment 135
Tax Topics - Income Tax Act - Section 221.2 - Subsection 221.2(1) no unpaid liability of non-resident to be reduced re appropriation of unrefunded s. 214(3)(a) tax 219

6 August 2014 External T.I. 2014-0519431E5 - Section 15(2.12)

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Tax Topics - Income Tax Act - Section 17.1 - Subsection 17.1(1) amended return not expected 215

18 June 2014 Internal T.I. 2014-0534541I7 - PLOI Elections

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23 May 2013 IFA Round Table Q. 6(c)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(11) 86

Subsection 15(2.13)

Administrative Policy

26 May 2016 IFA Roundtable Q. 11, 2016-0642031C6 - PLOI late-filed penalties

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Tax Topics - Income Tax Act - Section 212.3 - Subsection 212.3(13) aggregating A/R debits for penalty purposes under review 85

Subsection 15(2.16)

Finance

6 October 2017 APFF Financial Strategies and Instruments Roundtable, Q.13

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Specified Right right to secure shareholder debt is not per se a specified right 155

Paragraph 15(2.16)(c)

Subparagraph 15(2.16)(c)(i)

Clause 15(2.16)(c)(i)(B)

Administrative Policy

31 October 2017 External T.I. 2017-0690691E5 F - New section 15 back to back loan rules

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.16) - Paragraph 15(2.16)(c) - Subparagraph 15(2.16)(c)(ii) term deposit to secure shareholder loan potentially a specifed right 178
Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Specified Right pledged term deposit could be specified right 109

Subparagraph 15(2.16)(c)(ii)

Administrative Policy

31 October 2017 External T.I. 2017-0690691E5 F - New section 15 back to back loan rules

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.16) - Paragraph 15(2.16)(c) - Subparagraph 15(2.16)(c)(i) - Clause 15(2.16)(c)(i)(B) application to a term deposit pledged by a family corporation to secure a business loan taken out by a shareholder 182
Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Specified Right pledged term deposit could be specified right 109

14 September 2017 Roundtable, 2017-0703901C6 - CPA Alberta 2017 Q11: Shareholder loans

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Specified Right excluded provision of corporate security to secure repayment of a shareholder loan 159

Subsection 15(2.17)

Articles

Amanda S.A. Doucette, Britney Wangler, "Normal Borrowing by CCPC Owners Can Create an Income Inclusion", Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 1

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Finance

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Subsection 15(2.18)

Subsection 15(2.2) - When s. 15(2) not to apply — non-resident persons

Administrative Policy

21 June 1995 T.I. 951091 (see also 21 May 1996 T.I. 952686)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 93

Subsection 15(2.3) - When s. 15(2) not to apply — ordinary lending business

Administrative Policy

2012 Ruling 2011-0417711R3 -

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2007 Ruling 2007-0226281R3 - Withholding Exemption - Use of Finco

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8 February 2006 External T.I. 2004-0064811E5 - Subsection 15(2)

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2006 Ruling 2006-0211781R3 -

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2006 Ruling 2006-0191881R3 - Witholding Tax Exemption

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1996 Tax Executive Institute Round Table, Q. X (Draft, No. 963906)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.4) 63

Articles

John Lorito, Trevor O'Brien, "International Finance – Cash Pooling Arrangements", 2014 Conference Report, (Canadian Tax Foundation), 20:1-33

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Randy S. Morphy, "The Modern Approach to Statutory Interpretation, Applied to the Section 15 Anomaly in Foreign Affiliate Financing", Canadian Tax Journal, (2013) 61:2, 367-85:

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Guy Fortin, Melanie Beaulieu, "The Meaning of the Expressions ‘In the Ordinary Course of Business' and ‘Directly or Indirectly'", 2002 Conference Report (Toronto: Canadian Tax Foundation, 2003) 36:1-60.

Subsection 15(2.4) - When s. 15(2) not to apply — certain employees

See Also

Goreham v. The Queen, 2000 DTC 1561 (TCC)

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Lavoie v. The Queen, 95 DTC 673 (TCC)

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Kalousdian v. The Queen, 94 DTC 1722 (TCC)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 97

Spencer v. The Queen, 93 DTC 1222 (TCC)

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Kanters v. MNR, 92 DTC 1508 (TCC)

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Deckelbaum v. MNR, 82 DTC 1636 (T.R.B.)

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Words and Phrases
arrangement

Fabry v. MNR, 81 DTC 638 (T.R.B.)

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Hendriks v. MNR, 81 DTC 939 (T.R.B.)

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Reekie v. MNR, 80 DTC 1447 (T.R.B.)

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Altenhof v. MNR, 73 DTC 239 (T.R.B.)

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Administrative Policy

5 February 2002 External T.I. 2001-011547 -

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26 May 1997 T.I. 970545

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1996 Tax Executive Institute Round Table, Q. X (Draft, No. 963906)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.3) 121

11 August 1995 T.I. 950974 (C.T.O. "Shareholder/Employee Housing Loan")

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Income Tax Regulation News, Release No. 3, 30 January, 1995 under "Paragraph 15(2)(b) and 20(1)(j)"

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30 March 1994 Memorandum 933613 (C.T.O. "Allocation of S/H Loan to Farm and P/R")

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28 March 1994 T.I. 933225 (C.T.O. "Meaning of 'Dwelling'")

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17 June 1994 T.I. 933229 (C.T.O. "Shareholder Loans - Employee Gifts Loan to Spouse for Home")

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20 May 1994 T.I. 940083 (C.T.O. "Loan to a Shareholder")

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93 C.R. - Q. 17

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92 C.R. - Q.42

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30 November 1991 Round Table (4M0462), Q. 2.3 - Housing Loan (s.15(2)(a)(ii), I.T.A.) (C.T.O. September 1994)

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30 November 1991 Round Table (4M0462), Q. 2.1 - Automobile Loan (s.15(2)(a)(iv), I.T.A.) (C.T.O. September 1994)

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7 October 1991 T.I. (Tax Window, No. 10, p. 6, ¶1507)

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4 April 1991 T.I. (Tax Window, No. 2, p. 28, ¶1221)

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21 September 1990 T.I. (Tax Window, Prelim. No. 1, p. 7, ¶1002)

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86 C.R. - Q.61

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86 C.R. - Q.63

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Paragraph 15(2.4)(a)

See Also

Canadian Occidental U.S. Petroleum Corp. v. The Queen, 2001 DTC 295 (TCC)

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Paragraph 15(2.4)(e)

See Also

Mast v. The Queen, 2013 TCC 309

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Administrative Policy

4 November 2011 External T.I. 2011-0406271E5 - Sole Shareholder-Employee Home Purchase Loan

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18 February 2002 External T.I. 2002-011849 -

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9 January 2001 External T.I. 2000-005999 -

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IT-119R4 "Debts of Shareholders and Certain Persons Connected with Shareholders"

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Paragraph 15(2.4)(f)

See Also

Mast v. The Queen, 2013 TCC 309

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.4) - Paragraph 15(2.4)(e) requirement to repay at least 50% of principal over 10-year term, with balance at maturity, did not represent bona fide repayment arrangements 212

Davidson v. The Queen, 99 DTC 933 (TCC)

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Words and Phrases
arrangement
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Tax Topics - General Concepts - Evidence 37

Administrative Policy

24 April 2001 Internal T.I. 2001-006700 -

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IT-119R4 "Debts of Shareholders and Certain Persons Connected with Shareholders"

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Subsection 15(2.6) - When s. 15(2) not to apply — repayment within one year

See Also

Magicuts Inc. v. The Queen, 98 DTC 2085 (TCC)

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Ozawa v. The Queen, 97 DTC 1500 (TCC)

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Meeuse v. The Queen, 94 DTC 1397 (TCC)

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Uphill Holdings Ltd. v. MNR, 93 DTC 148 (TCC)

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Attis v. MNR, 92 DTC 1128 (TCC)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) 76

Docherty v. MNR, 91 DTC 537 (TCC)

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Tax Topics - General Concepts - Evidence set-off evidenced in working papers 77

Burgeo Trawlers Ltd. v. MNR, 91 DTC 231 (TCC)

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Taylor v. MNR, 87 DTC 475, [1987] 2 CTC 2178 (TCC)

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Administrative Policy

24 April 2015 External T.I. 2014-0560401E5 - Subsections 15(2) and 227(6.1) and Part XIII tax

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 227 - Subsection 227(6.1) repayment of assigned loan to assignee after 2 years 150

9 October 2015 APFF Roundtable Q. 19, 2015-0595621C6 F - Cash pooling and subsection 15(2)

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8 September 2014 External T.I. 2013-0482991E5 - 15(2) and related provisions

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.11) novation of pre-2012 loan 164
Tax Topics - Income Tax Act - Section 221.2 - Subsection 221.2(1) no unpaid liability of non-resident to be reduced re appropriation of unrefunded s. 214(3)(a) tax 219

2014 Ruling 2013-0505181R3 - 15(2.6) Series of Loans and Repayments

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10 January 2014 External T.I. 2013-0506571E5 F - Subsections 15(2) and 15(2.6)

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12 June 2012 STEP Roundtable, 2012-0442911C6 - STEP CRA Round Table - June 2012

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15 August 2012 External T.I. 2012-0443581E5 - Shareholder Loans

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17 February 2004 External T.I. 2003-0033915 -

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Tax Topics - General Concepts - Payment & Receipt no automatic set-off 75

2000 December TEI Roundtable, 2000-005603 -

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5 October 1992 External T.I. 5-921911 -

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92 C.R. - Q.44

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30 November 1991 Round Table (4M0462), Q. 3.4 - Series of Loans and Repayments (C.T.O. September 1994)

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18 January 1990 T.I. (June 1990 Access Letter, ¶1256)

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IT-119R4 "Debts of Shareholders and Certain Persons Connected With Shareholders" 7 August 1998

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Articles

Subsection 15(3) - Interest or dividend on income bond or debenture

Administrative Policy

IT-52R4 "Income Bonds and Income Debentures"

Subsection 15(5) - Automobile benefit

Cases

Meuse v. The Queen, 94 DTC 6640 (FCTD)

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Subsection 15(9)

Administrative Policy

16 August 2017 Internal T.I. 2015-0622751I7 - Part XIII Tax on Benefit to Non-resident

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) use of s. 160 to collect s. 15(9) liability of indirect FA on dividends paid to Canco 269
Tax Topics - Income Tax Act - Section 215 - Subsection 215(1) CFA liable for failure to "withhold" and remit Pt XIII tax on interest-free benefit on loan to NR sister of its Cdn grandparent 122
Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) s. 227.1 liability can extend to NR directors of a CFA 168
Tax Topics - Income Tax Act - Section 214 - Subsection 214(3) - Paragraph 214(3)(a) benefit from interest free loan by CFA to Canco sister deemed to be a dividend subject to Pt XIII tax 160
Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(2) extra-territorial application of s. 80.4(2) 132