(a)-(c)

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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IT-468R "Management or Administration Fees Paid to Non-residents" (Archived) 29 December 1999

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Paragraph 212(1)(b) - Interest

Cases

The Queen v. Immobiliare Canada Ltd., 77 DTC 5332, [1977] CTC 481 (FCTD)

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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

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Wenger's Ltd. v. MNR, 92 DTC 2132 (TCC)

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Havlik Enterprises Ltd. v. MNR, 89 DTC 159 (TCC)

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Inland Revenue Commissioners v. Oswald, [1945] A.C. 360, 26 TC 435

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Holder v. C.I.R., [1932] A.C. 624 (HL)

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Administrative Policy

5 September 2020 IFA Roundtable, Q.2

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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
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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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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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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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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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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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22 November 2000 External T.I. 2000-0049415 - Dividends - General

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16 November 2000 External T.I. 2000-0050975 - WITHHOLDING TAX ON SWAP PAYMENTS

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16 May 2000 External T.I. 2000-0011015 - WITHHOLDING TAX ON INDEX-LINKED INTEREST

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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

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IC-77-16R4 "Non-Resident Income Tax", 11 May 1992, para. 21

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28 March 1991 T.I. (Tax Window, No. 1, p. 19, ¶1173)

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27 March 1990 T.I. AC74543 [guaranteed interest received as interest]

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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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Wilson, "Selected Canadian Withholding Tax Issues", 1996 Cross-Border Taxation Issues and Developments, International Fiscal Association, p. 233

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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

Subparagraph 212(1)(b)(ii)

See Also

Munich Reinsurance Co. (Canada Branch) v. The Queen, 2000 DTC 2009 (TCC)

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Moran v. Pappas (1997), 34 OR (3d) 251 (Ont. Ct. (G.D.))

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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.)

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Re Canada Dairies Corp. Ltd. (1981), 131 DLR (3D) 605 (Ont. S.C.)

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Re McGruer & Clark Ltd (1976), 13 OR (2d) 385 (S.C.O.)

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R. v. Ontario Relations Board, Ex. P. Ontario Housing Corp. (1971), 19 DLR (3d) 47 (Ont HC)

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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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14 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 30, ¶1090)

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IT-155R3 "Exemption from Non-resident Tax on Interest Payable on Certain Bonds, Debentures, Notes, Hypothecs or Similar Obligations"

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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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Clause 212(1)(b)(iii)(C)

Cases

Munich Reinsurance Co. v. The Queen, 96 DTC 6185 (FCTD)

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Clause 212(1)(b)(iii)(D)

Administrative Policy

2005 Ruling 2005-0139661R3 - Withholding Index-Linked Notes

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87 C.R. - Q.1

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IT-360R2 "Interest Payable in a Foreign Currency"

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Articles

Wilkie, "Structuring International Debt Issues: A Canadian Perspective", Canadian Tax Journal, January/February 1987, p. 1

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Clause 212(1)(b)(iii)(E)

Cases

Kinguk Trawl Inc. v. Canada, 2003 DTC 5168, 2003 FCA 85

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Words and Phrases
agent

Cutlers Guild Ltd. v. The Queen, 81 DTC 5093, [1981] CTC 115 (FCTD)

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See Also

Kinguk Trawl Inc. v. The Queen, 2003 DTC 1524, 2003 TCC 842

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Subparagraph 212(1)(b)(vii)

Cases

General Electric Capital Equipment Finance Inc. v. Canada, 2002 DTC 6734, 2001 FCA 392

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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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Carma Developers Ltd. v. The Queen, 96 DTC 1798 (TCC), briefly aff'd 96 DTC 6569 (FCA)

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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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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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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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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"

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2004 Ruling 2004-0094751R3 - Withholding tax; interest

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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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2003 Ruling 2003-03924

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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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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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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 -

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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

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30 November 1995 Ruling 9629853 - CHANGE OF CONTROL TRIGGERING EVENT

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2 September 1998 Technical Interpretation 980737

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21 July 1999 External T.I. 9915455 - POST-AMBLE TO 212(l)(B)

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4 March 1999 Technical Interpretation 982412

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Income Tax Technical News, No. 15, "The Tax Consequences of the Adoption of the 'Euro' Currency"

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30 November 1997 Ruling 9813393 - XXXXXXXXXX - EVENT OF DEFAULT

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Income Tax Technical News, No. 11, Sept. 30, 1997

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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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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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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

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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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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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91 C.R. - Q. 50

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91 C.R. - Q. 17

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28 August 1991 Memorandum (Tax Window, No. 8, p. 23, ¶1434)

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19 August 1991 T.I. (Tax Window, No. 8, p. 22, ¶1431)

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9 August 1991 T.I. (Tax Window, No. 7, p. 22, ¶1391)

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29 July 1991 T.I. (C.T.O. Fax Service Doc. No. 305; Tax Window, No. 7, p. 12, ¶1374)

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10 June 1991 T.I. (Tax Window, No. 4, p. 23, ¶1289)

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23 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 5, ¶1038)

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(4) 20

25 January 1990 T.I. 5-8575

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2 January 1990 T.I. (June 1990 Access Letter, ¶1280)

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89 C.R. - Q. 1

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89 C.R. - Q. 2

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89 C.R. - Q. 3

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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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87 C.R. - Q. 2

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86 C.R. - Q. 11

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86 C.R. - Q. 12

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84 C.R. - Q. 38

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84 C.R. - Q. 60

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ATR-69, dated April 20, 1995

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ATR-49

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IT-155R3 "Exemption from Non-resident Tax on Interest Payable on Certain Bonds, Debentures, Notes, Hypothecs or Similar Obligations"

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IT-361R2 "Exemption from Tax on Interest Payments to Non-residents"

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Read, "Technical Matters", 83 C.R., p. 783

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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.

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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Richardson, "European Currency Unit: A Currency for All Seasons", Corporate Finance, Vo. 1, No. 2, 1992, p. 43

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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

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Wilkie, "Structuring International Debt Issues: A Canadian Perspective", Canadian Tax Journal, January-February 1987, page 1

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Couzin, "Canada: Withholding Tax and Interest", Tax Management International Journal, January 1982, page 14

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Loveland, "Income Tax Impediments to Foreign Investment in Canada", 1982 Conference Report, page 666

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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