Paragraph 212(1)(a) - Management fee
Cases
Peter Cundill & Associates Ltd. v. The Queen, 91 DTC 5085 (FCTD), aff'd 91 DTC 5543 (FCA)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | dependency on name fund manager and 50% owner | 180 |
| Tax Topics - Statutory Interpretation - Interpretation Bulletins, etc. | 13 | |
| Tax Topics - Statutory Interpretation - Noscitur a Sociis | 68 |
Administrative Policy
Paragraph 212(1)(b) - Interest
Cases
The Queen v. Immobiliare Canada Ltd., 77 DTC 5332, [1977] CTC 481 (FCTD)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) | sale of bond with accrued interest did not satisfy interest | 170 |
| Tax Topics - Income Tax Act - Section 246 - Subsection 246(1) | elimination of Part XIII tax was a s. 246(1) benefit | 89 |
| Tax Topics - Income Tax Act - Section 76 | 103 |
See Also
Kinguk Trawl Inc. v. The Queen, 2002 DTC 1399 (TCC), rev'd 2003 DTC, 2003 FCA 85
Wenger's Ltd. v. MNR, 92 DTC 2132 (TCC)
Havlik Enterprises Ltd. v. MNR, 89 DTC 159 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 215 - Subsection 215(2) | meaning of "or otherwise" | 63 |
| Tax Topics - Income Tax Act - Section 215 - Subsection 215(6) | 109 |
Inland Revenue Commissioners v. Oswald, [1945] A.C. 360, 26 TC 435
Administrative Policy
5 September 2020 IFA Roundtable, Q.2
2018 Ruling 2017-0732001R3 - XXXXXXXXXX
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|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | interest which the issuer can elect not to pay was treated as non-deductible | 186 |
2017 Ruling 2016-0649061R3 - Part XIII tax on payments on Notes
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | a perpetual note whose interest payments were optional had non-deductible interest | 218 |
13 July 2018 Internal T.I. 2017-0713301I7 - Assumption of accrued interest
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Words and Phrases
novation| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.1) - Paragraph 212(13.1)(a) | withholding when debt of Canadian partnership assumed by sub | 162 |
2014 Ruling 2014-0539791R3 - Paragraph 212(1)(b)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | interest paid on limited recourse debt to the extent of available debtor was not participating debt interest | 245 |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | creditors' approval of CCAA plan of compromise for the debtor trust did not cause them to not deal at arm's length with trust | 204 |
16 April 2014 External T.I. 2014-0525071E5 - Part XIII tax on interest payments
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23 January 2008 External T.I. 2007-0241391E5 - Withholding tax on payments made by a guarantor
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8 March 2007 Internal T.I. 2006-0214291I7 - Part XIII withholding tax
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2006 Ruling 2006-0208001R3 - Post-amble to paragraph 212(1)(b)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | participation based on mutual funds | 60 |
2005 Ruling 2005-0161521R3 - Postamble of 212(1)(b)
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | 99 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | variable interest tracked creditworthiness, not profitability | 99 |
7 May 2004 IFA Roundtable Q. 1, 2004-0072131C6 - IFA Round Table 2004 Q.1 - 212(13.1)(a)
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| Tax Topics - Treaties - Income Tax Conventions - Article 11 | 257 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.1) - Paragraph 212(13.1)(a) | where s. 212(13.1)(a) does not apply, it may be possible to consider a Canadian partner to be an interest payer | 221 |
19 February 2003 Internal T.I. 2002-0125767 - STRONG CURRENCY BORROWINGS
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8 January 2003 External T.I. 2002-0173135 - INTEREST POSTAMBLE
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | 43 |
9 October 2001 External T.I. 2001-009665 -
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | 42 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | acceptable to link to stock index or price of shares of dissimilar corporation | 102 |
13 July 2001 Internal T.I. 2000-0051017 - STRONG CURRENCY BORROWINGS
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Swaps | 110 |
22 November 2000 External T.I. 2000-0049415 - Dividends - General
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | stock index link | 139 |
| Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account | 67 |
16 November 2000 External T.I. 2000-0050975 - WITHHOLDING TAX ON SWAP PAYMENTS
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Clause 212(1)(b)(i)(C) | 48 |
16 May 2000 External T.I. 2000-0011015 - WITHHOLDING TAX ON INDEX-LINKED INTEREST
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | link to FX fluctuation acceptable | 123 |
24 November 1995 External T.I. 9508605 - WITHHOLDING TAX ON PRESCRIBED DEBT OBLIGATIONS
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5 July 1994 Internal T.I. 9334557 - PART XIII-POOLED COMMON TRUST FUNDS
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93 C.R. - Q. 31
IC-77-16R4 "Non-Resident Income Tax", 11 May 1992, para. 21
28 March 1991 T.I. (Tax Window, No. 1, p. 19, ¶1173)
27 March 1990 T.I. AC74543 [guaranteed interest received as interest]
84 C.R. - Q. 60
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Articles
Raj Juneja, "Taxation of equity derivatives", 2015 CTF Annual Conference paper
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Subparagraph 212(1)(b)(i)
Administrative Policy
3 December 1992 T.I. 921655 (C.T.O. "Factoring Accounts Receivable Whether Sale or Loan"; Tax Window, No. 26, p. 5, ¶2315)
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|---|---|---|
| Tax Topics - Income Tax Act - Section 16 - Subsection 16(1) | 53 |
Articles
John Tobin, "Infrastructure and P3 Projects", 2017 Conference Report (Canadian Tax Foundation), 10:1-31
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Subparagraph 212(1)(b)(ii)
See Also
Munich Reinsurance Co. (Canada Branch) v. The Queen, 2000 DTC 2009 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 121 |
Moran v. Pappas (1997), 34 OR (3d) 251 (Ont. Ct. (G.D.))
R. v. Eldorado Nuclear Ltd.; R. v. Uranium Canada Ltd. (1983), 4 DLR (4th) 193, [1983] 2 S.C.R. 551
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Sydney Steel Corp v. A.L.E. & C. Ltd. (1983), 148 DLR (3d) 348 (N.S. C.A.)
Re Canada Dairies Corp. Ltd. (1981), 131 DLR (3D) 605 (Ont. S.C.)
Re McGruer & Clark Ltd (1976), 13 OR (2d) 385 (S.C.O.)
Administrative Policy
29 August 1995 External T.I. 9506325 - SIMILAR OBLIGATIONS AND 212(1)(B)(II)(C)(II)
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91 C.R. - Q.40
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 146 - Subsection 146(1) - Qualified Investment | 14 |
14 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 30, ¶1090)
IT-155R3 "Exemption from Non-resident Tax on Interest Payable on Certain Bonds, Debentures, Notes, Hypothecs or Similar Obligations"
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| Tax Topics - Income Tax Act - Section 164 - Subsection 164(3) | 13 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | 40 |
Clause 212(1)(b)(i)(C)
Administrative Policy
16 November 2000 External T.I. 2000-0050975 - WITHHOLDING TAX ON SWAP PAYMENTS
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) | 33 |
Clause 212(1)(b)(iii)(C)
Clause 212(1)(b)(iii)(D)
Clause 212(1)(b)(iii)(E)
Subparagraph 212(1)(b)(vii)
Cases
General Electric Capital Equipment Finance Inc. v. Canada, 2002 DTC 6734, 2001 FCA 392
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | changes to 3 of the 4 fundamental attributes of debt produced new debt | 222 |
See Also
Lixo Investments Ltd. v. The Queen, 97 DTC 1030 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | 136 |
Carma Developers Ltd. v. The Queen, 96 DTC 1798 (TCC), briefly aff'd 96 DTC 6569 (FCA)
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a) | 182 |
Administrative Policy
2007 Ruling 2006-0218931R3 - Material Adverse Clause and Withholding Exemption
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2006 Ruling 2006-0211781R3 - Withholding Tax Exemption
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.3) | on-loan by special purpose sub in ordinary course | 62 |
2006 Ruling 2006-0195501R3 - Withholding Tax Exemption
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2006 Ruling 2006-0191881R3 - Witholding Tax Exemption
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 132 - Subsection 132(6) | loan guarantees | 56 |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.3) | 47 |
26 July 2005 External T.I. 2005-0134621E5 - Withholding Exemption
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2005 Ruling 2005-0161521R3 - Postamble of 212(1)(b)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) | variable interest tracked creditworthiness | 99 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | variable interest tracked creditworthiness, not profitability | 99 |
2005 Ruling 2005-0124081R3 - Withholding Tax Exemption
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2005 Ruling 2005-0133561R3 - withholding tax exemption
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2005 Ruling 2005-0119091R3 - Withholding tax; interest
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2004 Ruling 2004-0094741R3 - Withholding Exemption -Minimum EBITDA
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Draft GST/HST Policy Statement "Agreements and Novation"
2004 Ruling 2004-0094751R3 - Withholding tax; interest
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | 59 |
2004 Ruling 2004-0093591R3 - Withholding - GP corporation on loans to LP
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2004 Ruling 2004-0092731R3 - Withholding Tax exemption on-loan to a lp
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Income Tax Technical News, No. 30, 21 May 2004
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 103 - Subsection 103(1) | 36 | |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) | dollar amounts not artificial; parent lossco must have independent income source | 135 |
| Tax Topics - Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a) | 25 | |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) | no reserve if substantial peformance | 105 |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | 92 | |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | general partner cannot contract on its own account with partnership | 163 |
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(g) | 36 |
2003 Ruling 2003-03924
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) | 101 |
17 June 2003 External T.I. 2002-0178455 - NEW DEBT OBLIGATIONS; NOVATION
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2002 Ruling 2002-0167273 - WITHHOLDING EXCEPTION ASSET SALE
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3 July 2002 External T.I. 2002-0122185 - TWO TIERED PARTNERSHIP
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3 July 2002 External T.I. 2001-0084615 - ACCEPTABLE EVENTS OF DEFAULT
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2000 Ruling 2000-0029483 - Interest paid to non-residents
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9 October 2001 External T.I. 2001-009665 -
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) | stock index link | 102 |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest | acceptable to link to stock index or price of shares of dissimilar corporation | 102 |
17 September 2001 External T.I. 2001-0087185 - EVENT OF FAILURE OR DEFAULT
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4 December 2001 External T.I. 2001-0111455 - WITHHOLDING TAX EXEMPTION INTEREST
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2001 Ruling 2000-0060623 - Amendments to Notes - Disposition?
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 110 |
10 January 2001 External T.I. 2000-0007835 - EXEMP FROM WITHHOLDING TAX ON INTEREST
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6 March 2000 External T.I. 1999-001355 -
2000 Ruling 2000-0035043 - XXXXXXXXXX
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15 June 1999 External T.I. 9903035 - WITHHOLDING TAX
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1998 Ruling 9817073 - DISCOUNT BONDS
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1997 IFA Round Table, Q. 5, No. 9713180
30 November 1995 Ruling 9629853 - CHANGE OF CONTROL TRIGGERING EVENT
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | 57 |
2 September 1998 Technical Interpretation 980737
21 July 1999 External T.I. 9915455 - POST-AMBLE TO 212(l)(B)
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4 March 1999 Technical Interpretation 982412
Income Tax Technical News, No. 15, "The Tax Consequences of the Adoption of the 'Euro' Currency"
30 November 1997 Ruling 9813393 - XXXXXXXXXX - EVENT OF DEFAULT
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Income Tax Technical News, No. 11, Sept. 30, 1997
9 September 1997 External T.I. 9721405 - CONVERSION OF DEBT OBLIGATION
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| Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) | conversion conditional on issuer notice | 173 |
| Tax Topics - Income Tax Act - Section 51.1 | conversion subject to issuer notice | 173 |
Income Tax Technical News, No. 9, 10 February 1997
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Other Legislation/Constitution - Federal - Indian Act - Section 87 | 26 | |
| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | loss transfer must be to affiliated person - related not enough | 48 |
| Tax Topics - Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | 69 | |
| Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c.3) - Subparagraph 88(1)(c.3)(ii) | 151 | |
| Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(12) | 69 | |
| Tax Topics - Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) | avoidance of double taxation through absence of ACB adjustment | 129 |
30 November 1996 Ruling 9723563 - CHANGE OF CONTROL - LISTED EVENT OF DEFAULT
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30 November 1996 Ruling 9702203 - WITHHOLDING PART XIII
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30 November 1995 Ruling 9629853 - CHANGE OF CONTROL TRIGGERING EVENT
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Subparagraph 212(1)(b)(vii) | de facto change of control | 57 |
1996 TEI Round Table, Part VII, Q. B., 9640070
1996 Ruling 961368
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(9.1) | 64 |
18 January 1996 External T.I. 9530045 - COMMODITY REFERENCE IN PAYING INTEREST
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1996 Corporate Management Tax Conference Round Table, Q. 8
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(13.2) | 74 |
30 November 1995 Ruling 9623193 - WITHOLDING TAX ON INTEREST
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25 August 1995 External T.I. 9517335 - CONVERTIBLE DEBENTURES WITH ANTI-DILUTION CLAUSE
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10 December 1993 External T.I. 9333055 - WITHOLDING TAX EXEMPTION
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93 C.M.TC - Q. 8
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition | 48 |
93 C.M.TC - Q. 7
93 C.M.TC - Q. 6
92 C.M.TC - Q. 13
91 C.R. - Q. 50
91 C.R. - Q. 17
28 August 1991 Memorandum (Tax Window, No. 8, p. 23, ¶1434)
19 August 1991 T.I. (Tax Window, No. 8, p. 22, ¶1431)
9 August 1991 T.I. (Tax Window, No. 7, p. 22, ¶1391)
29 July 1991 T.I. (C.T.O. Fax Service Doc. No. 305; Tax Window, No. 7, p. 12, ¶1374)
10 June 1991 T.I. (Tax Window, No. 4, p. 23, ¶1289)
23 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 5, ¶1038)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(4) | 20 |
25 January 1990 T.I. 5-8575
2 January 1990 T.I. (June 1990 Access Letter, ¶1280)
89 C.R. - Q. 1
89 C.R. - Q. 2
89 C.R. - Q. 3
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) | 56 |
88 C.R. - "Finance and Leasing" - "Withholding Tax"
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| Tax Topics - Income Tax Act - Section 214 - Subsection 214(8) - Paragraph 214(8)(a) | 22 |
87 C.R. - Q. 2
86 C.R. - Q. 11
86 C.R. - Q. 12
84 C.R. - Q. 38
84 C.R. - Q. 60
ATR-69, dated April 20, 1995
ATR-49
IT-155R3 "Exemption from Non-resident Tax on Interest Payable on Certain Bonds, Debentures, Notes, Hypothecs or Similar Obligations"
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| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 164 - Subsection 164(3) | 13 | |
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) - Subparagraph 212(1)(b)(ii) | 11 |
IT-361R2 "Exemption from Tax on Interest Payments to Non-residents"
Articles
Robert A. Kopstein, Janette Y. Pantry, "Subparagraph 212(1)(b)(vii) Withholding Tax Exemption", 2005 Conference Report, c. 15.
Julie Colden, "Implications of Imperial Oil", Canadian Current Tax, Vol. 15, No. 3, December 2004, p. 21.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 214 - Subsection 214(8) - Paragraph 214(8)(c) | 0 |
Jack A. Silverson, "The New Trust Proposals in Section 212(1)(b)(vii)", Corporate Finance, Vol. VII, No. 2, 1999, p. 615.
Smith, "Recent Transactions: Debt", 1993 Conference Report, C. 19
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| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 19 |
Richardson, "European Currency Unit: A Currency for All Seasons", Corporate Finance, Vo. 1, No. 2, 1992, p. 43
Wilkie, "Issues Impacting on Exposure to Canadian Withholding Tax", Corporate Finance, Vol. 1, No. 1, 1992, p. 17.
Richardson, "Current Developments in Debt Financing: A Canadian Tax Perspective", 1988 Conference Report, C.22: Discussion of "poison puts".
Hansen, Richardson, "How Canadian Issuers Use Short-term Instruments", International Financial Law Review, February 1987, page 11
Wilkie, "Structuring International Debt Issues: A Canadian Perspective", Canadian Tax Journal, January-February 1987, page 1
Couzin, "Canada: Withholding Tax and Interest", Tax Management International Journal, January 1982, page 14
Paragraph 212(1)(c) - Estate or trust income
Administrative Policy
2014 Ruling 2013-0509431R3 - Part XIII tax and distributions from a trust
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| Tax Topics - Treaties - Income Tax Conventions - Article 22 | distributions to U.S. residents funded out of ROC payments and cross-border interest | 277 |
18 November 2011 External T.I. 2011-0422441E5 - Capital dividend paid to a Non-Resident
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(11) | redistribution of capital dividend subject to Part XIII tax | 194 |
9 October 2009 APFF Roundtable Q. 5, 2009-0327001C6 F - Succession canadienne - dividende en capital
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(11) | allocation of capital dividend between estate duties and NR distribution | 131 |
July 1990 Memorandum
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| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) | 32 |