(d)-(l)

Paragraph 20(1)(d) - Compound interest

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Tax Topics - General Concepts - Payment & Receipt	interest paid with loan	124
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Term Preferred Share		100
Tax Topics - Statutory Interpretation - Ordinary Meaning		62

Administrative Policy

S3-F6-C1 - Interest Deductibility

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Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(2)		2
Tax Topics - Income Tax Act - Section 16 - Subsection 16(1)		54
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures		10
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)		1181
Tax Topics - Income Tax Act - Section 20 - Subsection 20(3)		72
Tax Topics - Income Tax Act - Section 20.1 - Subsection 20.1(1)		92
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - 10/8 Policy		189
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(a)		83
Tax Topics - Income Tax Act - Section 67.5 - Subsection 67.5(1)		83
Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business		41
Tax Topics - General Concepts - Payment & Receipt		112

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

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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

syndicate

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

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Words and Phrases

syndicate

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)		143

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

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Words and Phrases

expense

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Tax Topics - General Concepts - Accounting Principles		14
Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a)		37
Tax Topics - Income Tax Regulations - Regulation 700 - Subsection 700(1)		116

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

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Tax Topics - General Concepts - Personality		105
Tax Topics - General Concepts - Separate Existence		110
Tax Topics - Income Tax Act - Section 167 - Subsection 167(5)		50
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a)		28
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	199
Tax Topics - Income Tax Act - Section 180 - Subsection 180(3)		26
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)	payment under guarantee not re borrowed money	169

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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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees		84
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing		73
Tax Topics - Income Tax Act - Section 9 - Accounting Principles		129
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange	borrowing to fund proposed acquisition (through Buyco) on capital account	156

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

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Words and Phrases

commission in the course of

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)		77

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

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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

commission

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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

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose	finding an acquirer to maximize shareholder value	164
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Shareholder Assistance		137
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)		179

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Tax Topics - General Concepts - Res Judicata		76
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure		133

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Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure		184
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose		111
Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc.		32

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Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition		24

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees		67

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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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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Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1)	interest-free loan	87
Tax Topics - Income Tax Act - Section 246 - Subsection 246(1)		247

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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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	35
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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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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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1)		100

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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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Timing		54

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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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

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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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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)

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

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2 November 89 T.I. (April 90 Access Letter, ¶1191)

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Short-Term Preferred Share		64
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a)		46

20 October 89 T.I. (March 1990 Access Letter, ¶1143)

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19 September 89 T.I. (February 1990 Access Letter, ¶1102)

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Tax Topics - Income Tax Act - Section 9 - Exempt Receipts/Business		19
Tax Topics - Income Tax Act - Section 9 - Expense Reimbursement		19

9 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1077)

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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

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87 C.R. - Q.50

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85 C.R. - Q. 19

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81 C.R. - Q. 21

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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

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Subparagraph 20(1)(e)(i)

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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	279
Tax Topics - Income Tax Act - Section 111 - Subsection 111(5.2)	stock option surrender payments of target deductible under s. 111(5.2)	58
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition	disposition of surrendered stock options occurred under doctrine of merger	287
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base	"cost" implies the acquisition of an asset	163

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	76

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	150

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	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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19 October 2005 Internal T.I. 2005-0151211I7 - Financing expenses

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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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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures		51

88 C.R. - "Finance and Leasing" - "Standby Charge, Guarantee Fee etc."

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Articles

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

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Tax Topics - Other Legislation/Constitution - British Columbia - Provincial Sales Tax Act - Section 1 - Tangible Personal Property		161
Tax Topics - Other Legislation/Constitution - British Columbia - Provincial Sales Tax Act - Section 1 - Taxable Services		88
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(l.1)		93
Tax Topics - Income Tax Act - Section 122.1 - Subsection 122.1(1) - Investment		164
Tax Topics - Income Tax Act - Section 13 - Subsection 13(27) - Paragraph 13(27)(b)		87
Tax Topics - Income Tax Act - Section 13 - Subsection 13(29)		173
Tax Topics - Income Tax Act - Section 18 - Subsection 18(6) - Paragraph 18(6)(c)		142
Tax Topics - Income Tax Act - Section 18 - Subsection 18(6) - Paragraph 18(6)(d)		52
Tax Topics - Income Tax Act - Section 21 - Subsection 21(1)		46
Tax Topics - Income Tax Act - Section 237.1 - Subsection 237.1(1) - Tax Shelter		79
Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(1) - Adjusted Stub Period Accrual Income		144
Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 14		98

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

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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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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Principal Amount		90
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange	capital loss on capital borrowing	137

Administrative Policy

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

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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	35
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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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)		75

Income Tax Technical News-41, 23 December 2009

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23 October 2002 Internal T.I. 2002-013579 -

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17 April 1997 Internal T.I. 7-970337 -

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

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Articles

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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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	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

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	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

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees		151

Administrative Policy

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

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	132

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

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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Locations of other summaries		Wordcount
Tax Topics - General Concepts - Accounting Principles		84
Tax Topics - General Concepts - Payment & Receipt	presumed application to oldest debt	93
Tax Topics - Income Tax Act - Section 10 - Subsection 10(1)		89

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

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Words and Phrases

debt

Picadilly 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		48
Tax Topics - Income Tax Act - Section 20 - Subsection 20(4)		47

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)		118
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i)	no bad debt history	42

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)		29

Administrative Policy

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

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19 March 1992 Memorandum 920775 (April 1993 Access Letter, p. 134, ¶C20-1140; Tax Window, No. 18, p. 6, ¶1820)

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

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IT-442R "Bad Debts and Reserves for Doubtful Debts"

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i)		85
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Account Receivable		161

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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Locations of other summaries		Wordcount
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

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(d)-(l)

Table of Contents

Paragraph 20(1)(d) - Compound interest

See Also

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

Administrative Policy

S3-F6-C1 - Interest Deductibility

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

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)

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

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

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

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)

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

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)

See Also

Emjo Holdings Ltd. v. The Queen, 2018 TCC 97 (Informal Procedure)

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

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

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 (TCC)

The Queen v. Royal Trust Corp. of Canada, 83 DTC 5172, [1983] CTC 159 (FCA)

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)

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

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

Administrative Policy

9 October 2015 APFF Roundtable Q. 1, 2015-0595751C6 F - Deductibility of financing fees and 20(1)(e)(v)

21 January 2015 Internal T.I. 2014-0547431I7 - "Excluded amount" under clause 20(1)(e)(iv.1)(C)

9 December 2013 External T.I. 2013-0507931E5 F - Financing fees

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

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

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

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

14 March 2007 External T.I. 2005-0161661E5 - Indirect Use of Funds

19 October 2005 Internal T.I. 2005-0151211I7 - Financing expenses

2004 APFF Roundtable Q. 34, 2004-008702 -

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

26 September 1997 T.I. 972511

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

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

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

4 October, 1994 T.I. 942335 (C.T.O. "Underwriter's Discount")

Revenue Canada Round Table TEI, 16 May 1994, Q. 11 (C.T.O. "Foreign Exchange Gains and Losses")

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

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

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)

20 October 89 T.I. (March 1990 Access Letter, ¶1143)

19 September 89 T.I. (February 1990 Access Letter, ¶1102)

9 Aug. 89 T.I. (Jan. 90 Access Letter, ¶1077)

89 C.M.T.C - "Participating Loans"

88 C.R. - "Finance and Leasing" - "Interest" - "Participating Loans"

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

79 C.R. - Q.6

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, 2018 TCC 170

Administrative Policy

7 October 2011 Roundtable, 2011-0412061C6 F - Financing Expenses

Subparagraph 20(1)(e)(ii.2)