Paragraph 20(1)(d) - Compound interest
See Also
MacNiven v. Westmoreland Investments Ltd., [2001] 1 All ER 865 (HL)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | interest paid with loan | 130 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Term Preferred Share | 104 | |
| Tax Topics - Statutory Interpretation - Ordinary Meaning | 70 |
Administrative Policy
29 September 2020 External T.I. 2018-0757501E5 F - Crédit pour intérêts sur les prêts étudiants
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.62 | capitalization of interest on a novation would constitute its payment – but novated loan would be a new non-student loan | 221 |
| Tax Topics - General Concepts - Payment & Receipt | capitalization of interest on a novation under Quebec law would constitute its payment | 214 |
S3-F6-C1 - Interest Deductibility
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21 April 2008 Internal T.I. 2007-0251761I7 F - Billet à payer
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) | addition of unpaid interest to principal was not a payment or crediting of the interest so as to engage Pt. XIII tax | 109 |
| Tax Topics - General Concepts - Payment & Receipt | addition of unpaid interest to principal was not a loan of money, nor a payment or crediting of interest | 159 |
88 C.R. - "Finance and Leasing" - "Interest" - "Deep Discount and Zero Coupon Bonds"
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 25 |
Articles
R. Couzin, "Income Tax Treatment of Financing Charges", 1980 Conference Report, p. 191.
Paragraph 20(1)(e) - Expenses re financing
Cases
Besse v. Canada, 99 DTC 5275 (FCA)
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Words and Phrases
syndicateKalthoff v. The Queen, 90 DTC 6378, [1990] 1 CTC 336 (FCTD), aff'd 92 DTC 6001 (FCA)
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Words and Phrases
syndicate| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 147 |
Macmillan Bloedel Ltd. v. The Queen, 90 DTC 6219, [1990] 1 CTC 468 (FCTD)
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Words and Phrases
expense| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Accounting Principles | 16 | |
| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) | 39 | |
| Tax Topics - Income Tax Regulations - Regulation 700 - Subsection 700(1) | 118 |
The Queen v. MerBan Capital Corp. Ltd., 89 DTC 5404, [1989] 2 CTC 246 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Personality | 107 | |
| Tax Topics - General Concepts - Separate Existence | 112 | |
| Tax Topics - Income Tax Act - Section 167 - Subsection 167(5) | 52 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) | 34 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures | guarantee fees paid respecting bank loans made to subsidiaries were capital expenditures | 207 |
| Tax Topics - Income Tax Act - Section 180 - Subsection 180(3) | 30 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | payment under guarantee not re borrowed money | 177 |
The Queen v. Antoine Guertin Ltée, 87 DTC 5458, 88 DTC 6126, [1988] 1 CTC 360 (FCA)
Neonex International Ltd. v. The Queen, 78 DTC 6339, [1978] CTC 485 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 92 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | 75 | |
| Tax Topics - Income Tax Act - Section 9 - Accounting Principles | 135 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange | borrowing to fund proposed acquisition (through Buyco) on capital account | 160 |
MNR v. Yonge-Eglinton Building Ltd., 74 DTC 6180, [1974] CTC 209 (FCA)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 79 |
Riviera Hotel Co. Ltd. v. MNR, 72 DTC 6142, [1972] CTC 157 (FCTD)
Consumers' Gas Co. v. MNR, 65 DTC 5138, [1965] CTC 225 (Ex Ct), briefly aff'd 67 DTC 5196 (SCC)
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Words and Phrases
commissionSee Also
Banque Laurentienne du Canada v. The Queen, 2020 CCI 73
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 67 | Crown failed to bring expert evidence as to the reasonableness of the fees | 277 |
Emjo Holdings Ltd. v. The Queen, 2018 TCC 97 (Informal Procedure)
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Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172, aff'd 2018 FCA 124
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 | 417 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | investment dealer fees re advisability of making hostile takeover were fully deductible | 529 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) | legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales | 182 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) | takeover bid circular costs did not qualify | 102 |
| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure | fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations | 365 |
| Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) | raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) | 246 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | expenses incurred in butterfly spin-off recognized as disposition expenses | 63 |
| Tax Topics - Statutory Interpretation - French and English Version | finding common meaning of 2 versions of s. 20(1)(bb) | 108 |
International Colin Energy Corp. v. The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | finding an acquirer to maximize shareholder value | 168 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Shareholder Assistance | 141 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 183 |
Sherway Centre Ltd. v. The Queen, 96 DTC 1640 (TCC), aff'd 98 DTC 6121 (FCA)
212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263, [1996] 1 CTC 2416 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Res Judicata | 80 | |
| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure | 137 |
The Queen v. Royal Trust Corp. of Canada, 83 DTC 5172, [1983] CTC 159 (FCA)
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Burrard Dry Dock Co. Ltd. v. MNR, 75 DTC 22, [1975] CTC 2011 (T.R.B.)
BACM Industries Ltd. v. MNR, 73 DTC 90, [1973] CTC 2093 (T.R.B.)
Terry v. MNR, 74 DTC 6017, [1973] CTC 837 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | 26 |
Les Laiteries Leclerc Inc. v. MNR, 71 DTC 702, [1971] Tax ABC 1061
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 69 |
Administrative Policy
9 October 2015 APFF Roundtable Q. 1, 2015-0595751C6 F - Deductibility of financing fees and 20(1)(e)(v)
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21 January 2015 Internal T.I. 2014-0547431I7 - "Excluded amount" under clause 20(1)(e)(iv.1)(C)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | payment to creditor excluded under s. 20(1)(e)(iv.1) as based on negotiated estimate of formula approximating equity value | 144 |
9 December 2013 External T.I. 2013-0507931E5 F - Financing fees
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures | intragroup cash pool utilization fees are capital expenditures | 224 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) | annual internal cash pool utilization fees likely are deductible under s. 20(1)(e.1) | 253 |
12 December 2012 Internal T.I. 2012-0464411I7 - Indirect Benefit
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) | interest-free loan | 113 |
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | 297 |
11 January 2013 External T.I. 2012-0436771E5 - Sale of a business
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9.1) | penalty paid by shareholder | 85 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | sale agreement required loan prepayment penalty | 68 |
Income Tax Technical News No. 44 13 April 2011 [archived]
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | inter-provincial loss shifting | 65 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) | exchangeable debenture appreciation not recognized | 106 |
| Tax Topics - Income Tax Act - Section 49 - Subsection 49(1) | exchangeable debenture exercise | 84 |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) | FMV basis in contributed property | 72 |
| Tax Topics - Treaties - Income Tax Conventions - Article 10 | use of s.à r.l. | 123 |
19 September 2008 Internal T.I. 2008-0272441I7 - GUILT LOCK DERIVATIVE
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Timing | 83 | |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures | derivative that effectively locked in effective interest rate on proposed bond issuance on income account | 115 |
14 March 2007 External T.I. 2005-0161661E5 - Indirect Use of Funds
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19 October 2005 Internal T.I. 2005-0151211I7 - Financing expenses
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) | indirect use test inapplicable to s. 20(1)(e) or (e.1), and “relate solely to … year” test not satisfied by lump sum issue fee reimbursement to parent | 243 |
8 October 2004 APFF Roundtable Q. 34, 2004-0087021C6 F - Remboursement de frais de financement
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|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv) | reimbursement of financing expenses | 99 |
4 March 2003 External T.I. 2002-0175705 - LOAN GUARANTEE
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) | up-front guarantee fee deductible under s. 20(1)(e) rather than s. 20(1)(e.1) | 181 |
5 June 1997 Internal T.I. 9704727 - SPECIAL WARRANT ISSUE COSTS
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) | 51 |
26 September 1997 External T.I. 9725115 - DEDUCTION OF PRE-SYNDICATION COSTS
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26 July 1996 Internal T.I. 9615787 - PROFESSIONAL FEES AND THEIR DEDUCTIBILITY
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10 July 1996 Internal T.I. 9618807 - DEDUCTIBILITY OF BORROWING COSTS - MONEY LENDERS
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|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing | 56 |
30 August 1995 External T.I. 9520955 - DEDUCTIBILITY OF AN EXCHANGE LOSS
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange | borrowing for capital purpose on capital account | 40 |
4 October 1994 External T.I. 9423355 - UNDERWRITER'S DISCOUNT
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Revenue Canada Round Table TEI, 16 May 1994, Q. 11 (C.T.O. "Foreign Exchange Gains and Losses")
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange | 67 |
Revenue Canada Round Table TEI, May 16, 1994, Q. XIII 9411060
1 April 1993 T.I. (Tax Window, No. 30, p. 20, ¶2500)
92 C.R. - Q.2
89 C.M.TC - Q.2
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | 46 |
10 January 1992 Memorandum (Tax Window, No. 17, p. 14, ¶1773)
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| Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) | 37 |
28 March 1991 T.I. (Tax Window, No. 1, p. 19, ¶1174)
23 February 1990 T.I. (July 1990 Access Letter)
2 November 89 T.I. (April 90 Access Letter, ¶1191)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Short-Term Preferred Share | 68 | |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 50 |
20 October 89 T.I. (March 1990 Access Letter, ¶1143)
19 September 89 T.I. (February 1990 Access Letter, ¶1102)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business | 21 | |
| Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement | 21 |
9 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1077)
89 C.M.T.C - "Participating Loans"
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 48 |
88 C.R. - "Finance and Leasing" - "Interest" - "Participating Loans"
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 29 |
88 C.R. - F.Q.3
87 C.R. - Q.50
85 C.R. - Q. 19
81 C.R. - Q. 21
81 C.R. - Q.39
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 63 |
79 C.R. - Q.6
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 39 | |
| Tax Topics - Income Tax Act - Section 67 | 13 |
Articles
R. Ian Crosbie, "Embedded Options: The Controversy as to Character", Corporate Finance, Vol VI, No. 4, p. 552.
Finance
Subparagraph 20(1)(e)(i)
See Also
Devon Canada Corporation v. The Queen, 2018 TCC 170
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure | payments made to target’s employees for surrendering their options on target’s acquisition were mostly deductible by it | 309 |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.2) | stock option surrender payments of target deductible under s. 111(5.2) | 62 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | disposition of surrendered stock options occurred under doctrine of merger | 318 |
| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | "cost" implies the acquisition of an asset | 172 |
Administrative Policy
7 October 2011 Roundtable, 2011-0412061C6 F - Financing Expenses
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) | property that is source only of capital gains cannot support a s. 20 deduction | 82 |
Subparagraph 20(1)(e)(ii)
Subparagraph 20(1)(e)(ii.2)
Administrative Policy
7 October 2011 Roundtable, 2011-0412021C6 F - Financing Expenses
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|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(2.2) | s. 12(2.2) might apply to on-charge, to ultimate group recipient of financing, of the financing expenses | 158 |
Paragraph 20(1)(e.1) - Annual fees, etc.
Administrative Policy
9 December 2013 External T.I. 2013-0507931E5 F - Financing fees
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|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures | intragroup cash pool utilization fees are capital expenditures | 224 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | cash pool utilization fees could be deductible under s. 20(1)(e) | 206 |
12 August 2010 Internal T.I. 2009-0328671I7 - Deduction pursuant to paragraph 20(1)(e)
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19 October 2005 Internal T.I. 2005-0151211I7 - Financing expenses
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | reimbursement by sub | 153 |
4 March 2003 External T.I. 2002-0175705 - LOAN GUARANTEE
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | up-front guarantee fee within scope of s. 20(1)(e) | 144 |
September 1990 T.I. 1990-101
10 May 1990 T.I. (October 1990 Access Letter, ¶1455)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures | 53 |
Articles
Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.
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Boulton, "Bankers' Acceptances Smooth Canadian-U.S. Cross-Border Credit", International Financial Law Review, November 1996, p. 32.
Paragraph 20(1)(e.2) - Premiums on life insurance used as collateral
Administrative Policy
26 November 2013 External T.I. 2012-0449631E5 F - Amount deductible under paragraph 20(1)(e.2)
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May 1999 CALU Conference No. 9908430 Q.10
30 September 1994 Internal T.I. 9414527 - BORROWINGS & EXCESS INSURANCE COLLATERAL
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1 August 1991 Memorandum (Tax Window, No. 7, p. 3, ¶1381)
IT-309R2 "Premiums on Life Insurance used as Collateral"
Paragraph 20(1)(f) - Discount on certain obligations
Cases
Provigo Inc. v. Canada, 2009 DTC 5877, 2008 FCA 205
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Imperial Oil Ltd. v. Canada; Inco Ltd. v. Canada, 2006 DTC 6639, 2006 SCC 46, [2006] 2 S.C.R. 447
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Principal Amount | 96 | |
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange | capital loss on capital borrowing | 151 |
Administrative Policy
Income Tax Technical News No. 44 13 April 2011 [archived]
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | inter-provincial loss shifting | 65 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | exchangeable debenture appreciation not recognized | 90 |
| Tax Topics - Income Tax Act - Section 49 - Subsection 49(1) | exchangeable debenture exercise | 84 |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) | FMV basis in contributed property | 72 |
| Tax Topics - Treaties - Income Tax Conventions - Article 10 | use of s.à r.l. | 123 |
29 October 2010 Internal T.I. 2010-0357241I7 - Exchangeable Debenture
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 77 |
14 January 2010 Internal T.I. 2009-0323991I7 F - Débenture échangeable et opération à terme
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges | premium was paid on capital account in closing out a cash-settled forward entered into in order to monetize a shareholding | 221 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) | CRA position of applying changes in published policy prospectively | 105 |
| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | full deduction of amounts only partly, or not, deductible under s. 20(1)(f) would have caught the eye of a wise and prudent person reviewing the return | 134 |
Income Tax Technical News-41, 23 December 2009
23 October 2002 Internal T.I. 2002-0135797 - FOREIGN EXCHANGE LOSSES
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Articles
Jim Samuel, Byron Beswick, "Selected Issues in Transactions Involving Debt", 2019 Conference Report (Canadian Tax Foundation), 18:1 – 27
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Paragraph 20(1)(g) - Share transfer and other fees
Cases
Canada v. Rio Tinto Alcan Inc., 2018 FCA 124
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Words and Phrases
financial report| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management | dealer and professional fees incurred by a public board in determining to make a bid, as contrasted to implementation, were currently deductible | 348 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | deduction was available for advisory fees respecting proposed acquisitin or divestiture of a whole company | 492 |
See Also
Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172, aff'd 2018 FCA 124
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | investment dealer fees incurred respecting the advisability of making hostile takeover were fully deductible under s. 9 | 417 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) | investment dealer fees re advisability of making hostile takeover were fully deductible | 529 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(cc) | legal fees incurred in securing regulatory approval for a hostile bid related to the bidder's business of earning income from shares and interaffiliate sales | 182 |
| Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure | fees incurred in order to acquire shares were excluded/butterfly expenses excluded as taxpayer was not in the business of implementing corporate reorganizations | 365 |
| Tax Topics - Income Tax Act - Section 169 - Subsection 169(2.1) | raising general question of deductibility of fees and listing s. 20(1)(e) did not satisfy s. 165(1.11) | 246 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) | failure to advance evidence showing allocation of fees to share consideration | 139 |
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | expenses incurred in butterfly spin-off recognized as disposition expenses | 63 |
| Tax Topics - Statutory Interpretation - French and English Version | finding common meaning of 2 versions of s. 20(1)(bb) | 108 |
Boulangerie St-Augustin Inc. v. The Queen, 95 DTC 164 (TCC), briefly aff'd 97 DTC 5012 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | 159 |
Administrative Policy
Paragraph 20(1)(j) - Repayment of loan by shareholder
Administrative Policy
12 June 2012 STEP Roundtable, 2012-0442911C6 - STEP CRA Round Table - June 2012
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) | repayment by executors | 140 |
92 C.R. - Q.44
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) | 56 |
92 C.R. - Q.43
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) | 29 |
Articles
Wilson, "Repayment of Shareholder Loans", 1995 Canadian Tax Journal, Vol. 43, No. 3, p. 746.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Payment & Receipt | 10 |
Paragraph 20(1)(l) - Doubtful or impaired debts
Cases
Groscki v. Canada, 2011 DTC 5097 [at 5886], 2011 FCA 174
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Langdon v. Canada, 2000 DTC 6203 (FCA)
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Words and Phrases
includedBell v. The Queen, 92 DTC 6064, [1992] 1 CTC 35 (FCTD)
Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Accounting Principles | 94 | |
| Tax Topics - General Concepts - Payment & Receipt | presumed application to oldest debt | 103 |
| Tax Topics - Income Tax Act - Section 10 - Subsection 10(1) | consistent LIFO use generally is acceptable | 99 |
Gibraltar Mines Ltd. v. The Queen, 83 DTC 5294, [1983] CTC 261 (FCA)
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Words and Phrases
debtPicadilly Hotels Ltd. v. The Queen, 78 DTC 6444, [1978] CTC 658 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Disposition of Property | 50 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(4) | 49 |
Harlequin Enterprises Ltd. v. The Queen, 77 DTC 5164, [1977] CTC 208 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) | 120 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | no bad debt history | 44 |
Simpson v. The Queen, 76 DTC 6350, [1976] CTC 600 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 98 - Subsection 98(1) | 31 |
See Also
Delle Donne v. The Queen, 2015 TCC 150
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Words and Phrases
included| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract | "debt" exists irrespective of demand | 99 |
| Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) | reserve could be claimed on appeal | 90 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) | bad debt deduction taken as at Dec. 31 in light of information available at April 30, and could be claimed implicitly or on appeal | 478 |
Cloverdale Paint Inc. v. The Queen, 2007 DTC 243, 2006 TCC 628
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Onus | 112 |
Administrative Policy
26 July 1995 External T.I. 9515735 - BAD DEBTS - FINANCIAL INSTITUTIONS
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