(d)-(l)

Paragraph 20(1)(d) - Compound interest

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MacNiven v. Westmoreland Investments Ltd., [2001] 1 All ER 865 (HL)

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88 C.R. - "Finance and Leasing" - "Interest" - "Deep Discount and Zero Coupon Bonds"

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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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syndicate

Kalthoff v. The Queen, 90 DTC 6378 (FCTD), aff'd 92 DTC 6001 (FCA)

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Macmillan Bloedel Ltd. v. The Queen, 90 DTC 6219 (FCTD)

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expense

The Queen v. MerBan Capital Corp. Ltd., 89 DTC 5404 (FCA)

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The Queen v. Antoine Guertin Ltée, 87 DTC 5458, 88 DTC 6126, [1988] 1 CTC 360 (FCA)

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Neonex International Ltd. v. The Queen, 78 DTC 6339, [1978] CTC 485 (FCA)

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MNR v. Yonge-Eglinton Building Ltd., 74 DTC 6180, [1974] CTC 209 (FCA)

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Riviera Hotel Co. Ltd. v. MNR, 72 DTC 6142, [1972] CTC 157 (FCTD)

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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

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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. 9 393
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 515
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 170
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(g) takeover bid circular costs did not qualify 96
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 343
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) 228
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 61
Tax Topics - Statutory Interpretation - French and English Version finding common meaning of 2 versions of s. 20(1)(bb) 102

International Colin Energy Corp. v. The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)

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Sherway Centre Ltd. v. The Queen, 96 DTC 1640 (TCC), aff'd 98 DTC 6121 (FCA)

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212535 Oil & Gas Ltd. v. MNR, 96 DTC 1263 (TCC)

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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.)

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BACM Industries Ltd. v. MNR, 73 DTC 90, [1973] CTC 2093 (T.R.B.)

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Terry v. MNR, 74 DTC 6017, [1973] CTC 837 (FCA)

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Les Laiteries Leclerc Inc. v. MNR, 71 DTC 702, [1971] Tax ABC 1061

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Enterprise Foundry Co. Ltd. v. MNR, 59 DTC 318, 22 Tax ABC 137

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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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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 share value 142

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 210
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) 241

12 December 2012 Internal T.I. 2012-0464411I7 - Indirect Benefit

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11 January 2013 External T.I. 2012-0436771E5 - Sale of a business

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(9.1) penalty paid by shareholder 83
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 60

Income Tax Technical News No. 44 13 April 2011 [archived]

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19 September 2008 Internal T.I. 2008-0272441I7 - GUILT LOCK DERIVATIVE

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Tax Topics - Income Tax Act - Section 9 - Timing 81
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 111

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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2004 APFF Roundtable Q. 34, 2004-008702 -

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5 June 1997 Internal T.I. 7-970472 -

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) 49

26 September 1997 T.I. 972511

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26 July 1996 Internal T.I. 7-961578 -

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10 July 1996 Memorandum 961880 (CTO "Deductibility of Borrowing Costs - Moneylenders")

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30 August 1995 T.I. 952095 (C.T.O. "Deductibility of an Exchange Loss")

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4 October, 1994 T.I. 942335 (C.T.O. "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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Revenue Canada Round Table TEI, May 16, 1994, Q. XIII 9411060

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1 April 1993 T.I. (Tax Window, No. 30, p. 20, ¶2500)

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92 C.R. - Q.2

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89 C.M.TC - Q.2

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

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28 March 1991 T.I. (Tax Window, No. 1, p. 19, ¶1174)

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23 February 1990 T.I. (July 1990 Access Letter)

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R. Ian Crosbie, "Embedded Options: The Controversy as to Character", Corporate Finance, Vol VI, No. 4, p. 552.

Finance

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Paragraph 20(1)(e.1) - Annual fees, etc.

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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 210
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) 192

12 August 2010 Internal T.I. 2009-0328671I7 - Deduction pursuant to paragraph 20(1)(e)

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) reimbursement by sub 147

September 1990 T.I. 1990-101

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10 May 1990 T.I. (October 1990 Access Letter, ¶1455)

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Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.

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Paragraph 20(1)(e.2) - Premiums on life insurance used as collateral

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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

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30 September 1994 Memorandum 941452 (C.T.O. "Borrowings & Excess Insurance Collateral")

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1 August 1991 Memorandum (Tax Window, No. 7, p. 3, ¶1381)

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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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Income Tax Technical News No. 44 13 April 2011 [archived]

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29 October 2010 Internal T.I. 2010-0357241I7 - Exchangeable Debenture

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30 July 1990 Decision Summary 90063 (Tax Window, Prelim. No. 1, p. 9, ¶1000)

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Smith, "Recent Transactions: Debt", 1993 Conference Report, p. 19:14

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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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financial report
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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 336
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 472

See Also

Rio Tinto Alcan Inc. v. The Queen, 2016 TCC 172

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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. 9 393
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 515
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 170
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 343
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) 228
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 131
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 61
Tax Topics - Statutory Interpretation - French and English Version finding common meaning of 2 versions of s. 20(1)(bb) 102

Boulangerie St-Augustin Inc. v. The Queen, 95 DTC 164 (TCC), briefly aff'd 97 DTC 5012 (FCA)

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30 November 1991 Round Table (4M0462), Q. 5.2 - Fees for an Impartial Opinion (C.T.O. September 1994)

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Paragraph 20(1)(j) - Repayment of loan by shareholder

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

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) repayment by executors 132

92 C.R. - Q.44

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) 56

92 C.R. - Q.43

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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.

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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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included

Bell v. The Queen, 92 DTC 6064 (FCTD)

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Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).

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Gibraltar Mines Ltd. v. The Queen, 83 DTC 5294, [1983] CTC 261 (FCA)

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debt

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

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Harlequin Enterprises Ltd. v. The Queen, 77 DTC 5164, [1977] CTC 208 (FCA)

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Simpson v. The Queen, 76 DTC 6350, [1976] CTC 600 (FCTD)

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Tax Topics - Income Tax Act - Section 98 - Subsection 98(1) 29

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Delle Donne v. The Queen, 2015 TCC 150

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included
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Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract "debt" exists irrespective of demand 87
Tax Topics - Income Tax Act - Section 171 - Subsection 171(1) reserve could be claimed on appeal 82
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 452

Cloverdale Paint Inc. v. The Queen, 2007 DTC 243, 2006 TCC 628

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92735 Canada Ltd. v. The Queen, 99 DTC 771 (TCC)

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26 July 1995 T.I. 951573 (C.T.O. "Bad Debts - Financial Institutions")

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2 July 1991 T.I. (Tax Window, No. 5, p. 18, ¶1325)

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Subparagraph 20(1)(l)(ii)

Articles

Arthur Driedger, Stephen Wong, "IFRS 9: Financial Instruments", Canadian Tax Highlights, Vol. 26, No. 6, June 2018, p.6

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