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...
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|---|---|---|
| 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...
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|---|---|---|
| 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...
| 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...