Section 17.1

Subsection 17.1(1) - Deemed interest income — sections 15 and 212.3

Administrative Policy

6 September 2023 Internal T.I. 2019-0805481I7 - Interaction of 17.1(1) & 247(2)

A corporation resident in Canada (“CRIC”) made various loans to an indirect wholly-owning parent which bore interest, payable at least...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2.1) there is no conflict in applying both ss. 17.1 and 247(2) to impute interest on a PLOI 272

6 August 2014 External T.I. 2014-0519431E5 - Section 15(2.12)

Is the CRIC required to file an amended return, on late-filing a PLOI election, to reflect the additional s. 17.1(1) interest income? CRA...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.11) amended return not expected/CRA will assess Part XIII tax after 2 years if late election not yet filed 231

4 June 2014 External T.I. 2014-0517151E5 - S. 17.1 and debt denominated in foreign currency

A non-resident corporation owes a foreign-currency denominated amount to a CRIC which is a pertinent loan or indebtedness (a "PLOI"), as defined...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) prescribed interest on foreign currency PLOI translated at spot rate when loan made 194

23 May 2013 IFA Round Table Q. 6(e)

In respect of component (ii) of variable A in s. 17.1(1)(b), the correspondent asked:

Could the indirectly funded rule in s. 17.1(1)(b) be avoided...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.