(3)-(29)

Subsection 20(3) - Borrowed money

Cases

The Queen v. Shore, 92 DTC 6059 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

24 August 1994 T.I. 942051 (C.T.O. "Interest Deductibility")

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 January 1993 T.I. (Tax Window, No. 28, p. 10, ¶2395)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 20(4) - Bad debts from dispositions of depreciable property

Cases

Picadilly Hotels Ltd. v. The Queen, 78 DTC 6444, [1978] CTC 658 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Belle-Isle v. MNR, 64 DTC 5041 (Ex Ct), briefly aff'd 66 DTC 5100, [1966] R.C.S. 354

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

4 September 1991 T.I. (Tax Window, No. 10, p. 17, ¶1473)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-220R2 "Capital Cost Allowance - Proceeds of Disposition of Depreciable Property" under "Bad Debts"

Subsection 20(5) - Sale of agreement for sale, mortgage or hypothecary claim included in proceeds of disposition

Administrative Policy

IT-323 "Sale of Mortgage Included in Proceeds of Disposition of Depreciable Property"

Subsection 20(7) - Where para. (1)(m) does not apply

Paragraph 20(7)(a)

Cases

Sears Canada Inc. v. The Queen, 86 DTC 6304, [1986] 2 CTC 80 (FCTD), aff'd 89 DTC 5039 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Amesbury Distributors Ltd. v. The Queen, 85 DTC 5076, [1984] CTC 667 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Mister Muffler Ltd. v. The Queen, 74 DTC 6615, [1974] CTC 813 (FCTD)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Redhead Equipment Ltd. v. The Queen, 2001 DTC 429 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) reserve for future inspection costs down adjustable based on hindsight 130

Dubawn Holdings Inc. v. The Queen, 94 DTC 1252 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(e) deducted if factually deducted 75

Administrative Policy

89 C.R. - Q.21

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 20(10) - Convention expenses

Cases

See Also

Administrative Policy

6 October 2017 APFF Roundtable, Q.12

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Know-How and Training convention expenses "historically" viewed as capital expenditures 63

1 March 2013 External T.I. 2013-0477911E5 - Expenses to host employees and spouses at a resort

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Novek, "Convention Expenses Are Subject to Territorial Limitations", Taxation of Executive Compensation and Retirement, February 1992, p. 557.

Subsection 20(11) - Foreign taxes on income from property exceeding 15%

Administrative Policy

3 February 2016 External T.I. 2014-0548111E5 - U.S. tax paid in respect of an LLC's income

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 88 - Subsection 88(3) - Paragraph 88(3)(d) no deemed dividend 124
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax LLC tax paid by Cdn member not re business 163
Tax Topics - Income Tax Act - Section 20 - Subsection 20(12) s. 20(14) deduction for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 418
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) FTC for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 316
Tax Topics - Treaties - Articles of Treaties - Article 24 Treaty sourcing rule does not trench on domestic FTC 208

10 June 2013 STEP CRA Roundtable, 2013-0480301C6 - 2013 STEP CRA Roundtable – Question 4

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

10 June 2013 STEP Roundtable, 2013-0480371C6 - 2013 STEP Question 13 - US LLCs and 20(11)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

3 March 1997 Memorandum 964132

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Treaties - Articles of Treaties - Article 24 16

84 C.R. - Q.34

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

IT-506 "Foreign Income Taxes as a Deduction from Income"

Articles

Manjit Singh, Andrew Spiro, "The Canadian Treatment of Foreign Taxes", 2014 Conference Report, (Canadian Tax Foundation), 22:1-37

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 20(12) - Foreign non-business income tax

Cases

FLSmidth v. The Queen, 2013 DTC 5118 [at 6147], 2013 FCA 160, aff'g infra

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

FLSmidth Ltd. v. The Queen, 2012 DTC 1052 [at 2745], 2012 TCC 3, aff'd 2013 DTC 5118 [at 6147], 2013 FCA 160

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Kaiser v. MNR, 91 DTC 1057 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Headings 48

Administrative Policy

3 February 2016 External T.I. 2014-0548111E5 - U.S. tax paid in respect of an LLC's income

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 88 - Subsection 88(3) - Paragraph 88(3)(d) no deemed dividend 124
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax LLC tax paid by Cdn member not re business 163
Tax Topics - Income Tax Act - Section 20 - Subsection 20(11) only income was taxable capital gains 131
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) FTC for US operating-income taxes imposed on Cdn LLC member even where his only Cdn income from LLC is taxable capital gain 316
Tax Topics - Treaties - Articles of Treaties - Article 24 Treaty sourcing rule does not trench on domestic FTC 208

15 December 2015 Internal T.I. 2014-0560371I7 - Subsection 20(12) deduction

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

7 March 2016 Internal T.I. 2015-0572461I7 - Foreign tax deduction

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

11 June 2013 STEP Roundtable, 2013-0480321C6 - 2013 STEP Question 6 US LLCs - FAPI, FAT and FTCs

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

28 May 2013 Internal T.I. 2013-0476381I7 - Deemed Resident Trusts & Foreign Tax Credit

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) no pro-ration of FTC by s. 94 trust where Canadian gain was smaller than US gain 283
Tax Topics - Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(b) 283

18 July 2011 Internal T.I. 2011-0394631I7 - Foreign non-business income tax

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

1 October 2008 T.I. 2006-0174701E5

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

22 July 2008 Internal T.I. 2008-0284351I7

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Words and Phrases
paid for the year

10 January 2005 External T.I. 2004-007593

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

19 March 2004 External T.I. 2003-003730 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

10 April 2003 External T.I. 2003-0003095 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

21 February 2000 T.I. 1999-0010295

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

10 February 1993 Memo 9300776

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

20 November 1992 T.I. 123456 (September 1993 Access Letter, p. 410, ¶C20-1160)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

October 1992 Central Region Rulings Directorate Tax Seminar, Q. J (May 1993 Access Letter, p. 231)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

25 March 1991 Memo 7-4727

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax US withholding on share redemption was income tax 81

88 C.R. - Q.57

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

16 July 1985 Memo 7-4095

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 20(14) - Accrued bond interest

Cases

Canada v. Antosko, 94 DTC 6314, [1994] 2 S.C.R. 312

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Mitchell v. The Queen, 96 DTC o (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Husain v. MNR, 91 DTC 278 (TCC)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

92 C.R. - Q.1

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

90 C.R. - Q.13

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Ewens, "Debt-for-Debt Exchanges", 1991 Canadian Tax Journal, p. 615

Ulmer, "Taxation of Interest Income", 1990 Conference Report, pp. 8:19-20

Subsection 20(16) - Terminal loss

Cases

May Bros. Farm Ltd. v. The Queen, 92 DTC 6342 (FCA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

See Also

Benedict v. The Queen, 2012 DTC 1170 [at 3419], 2012 TCC 174 (Informal Procedure)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Greater Toronto Airports Authority v. International Lease Finance Corp. (2004), 69 OR (3d) 1 (CA)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Administrative Policy

93 C.P.T.J. - Q.25

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

13 May 1991 T.I. (Tax Window, No. 3, p. 15, ¶1231)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Subsection 20(16.1)

Administrative Policy

S3-F4-C1 - General Discussion of Capital Cost Allowance

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense 476
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A 669
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property 170
Tax Topics - Income Tax Act - Section 16.1 - Subsection 16.1(1) 248
Tax Topics - Income Tax Act - Section 13 - Subsection 13(28) 194
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) 178
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29) 145
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2) 184
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(2.2) 267
Tax Topics - Income Tax Regulations - Regulation 1100 - Subsection 1100(3) 60
Tax Topics - Income Tax Act - Section 18 - Subsection 18(3.1) 140
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7.5) 167
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) 53
Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) 204
Tax Topics - Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) 150
Tax Topics - Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) 55
Tax Topics - Income Tax Act - Section 43 - Subsection 43(1) 142
Tax Topics - Income Tax Act - Section 68 153
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(a) 65
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) 117
Tax Topics - Income Tax Act - Section 13 - Subsection 13(1) 403
Tax Topics - Income Tax Act - Section 8 - Subsection 8(2) 65
Tax Topics - Income Tax Act - Section 13 - Subsection 13(9) 207
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) 299
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 8 214
Tax Topics - Income Tax Act - Section 13 - Subsection 13(5) 259
Tax Topics - Income Tax Act - Section 13 - Subsection 13(6) 191

Subsection 20(21) - Debt obligation

Administrative Policy

19 March 1992 Memorandum (Tax Window, No. 18, p. 6, ¶1820)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Ewens, "Debt-for-Debt Exchanges", 1991 Canadian Tax Journal, p. 615: Discussion of potential deduction to holders of debentures in a target corporation for arrears of interest realized under s. 76(1).

Subsection 20(24) - Amounts paid for undertaking future obligations

Administrative Policy

2015 Ruling 2014-0552871R3 - Split-Up Butterfly

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution post-butterfly sale of distributed shares by TC1 to TC2/disproportionate split of CDA/assumption of prepaid rent (for which a 20(24) election) treated as boot 709
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(b) post-butterfly sale of distributed shares by one TC to the other 59

8 December 2010 External T.I. 2010-0375921E5 - Subsection 20(24)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

7 March 2005 External T.I. 2005-011498 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

20 November 2003 External T.I. 2003-003354 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) continuity under s. 98(5) 78

15 November 1999 External T.I. 5-992458 -

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) lowering of sale price 84

June 1991 Memorandum (Tax Window, No. 4, p. 18, ¶1274)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

22 April 1991 Memorandum (Tax Window, No. 2, p. 24, ¶1192)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

5 June 1990 TI File 7-4678

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Articles

Ron Choudhury, "Non-Resident Issues in Acqusition Transactions", 2005 Conference Report (Canadian Tax Foundation), 42:9-16.

Bergen, "Purchase and Sale of Assets: An Update", 1996 Corporate Management Tax Conference Report, pp. 3:6-8.

Subsection 20(29) - Idem [Deduction before available for use]

Administrative Policy

13 April 1992 T.I. (Tax Window, No. 18, p. 13, ¶1843)

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.