Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 132 - Subsection 132(5.3) - Paragraph 132(5.3)(b)		100
Tax Topics - Income Tax Act - Section 104 - Subsection 104(7.1)		75
Tax Topics - Income Tax Act - Section 132 - Subsection 132(5.3) - Paragraph 132(5.3)(a)		141
Tax Topics - Income Tax Act - Section 132 - Subsection 132(4) - Capital Gains Redemption		106
Tax Topics - Income Tax Act - Section 132 - Subsection 132(5.31)		377
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(2) - Paragraph 251.2(2)(b)		133
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(1) - Investment Fund		354
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c)		250
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Eligible Group Entity		192
Tax Topics - Income Tax Act - Section 94 - Subsection 94(1) - Fixed Interest		72

A

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Creation of non-capital loss in carryback or carryforward year (pp. 18-19)

An example is provided where a portion of a non-capital loss that is...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (b)		222
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		90
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		92
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iv)		213
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		323
Tax Topics - Income Tax Act - Section 80 - Subsection 80(3)		44
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B		212
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (e)		194

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Double-deductions of non-capital losses

Item A in the ATI formula is reduced by the non-capital loss and net capital loss generated for the...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(2)		77
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Expenses - A - Paragraph (d)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(3)		113
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		73
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Acceptable Accounting Standards		85
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		66
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4) - Paragraph 18.2(4)(c)		104

D

Paragraph D(a)

Articles

Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter

A(D)(a) should be permitted to be a negative number (p. 7)

In order to permit the carry back or carry forward of losses sufficient to fully...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		207
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		243
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Revenues		123
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Eligible Group Entity - Paragraph (a)		107
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		119

Paragraph D(b)

Administrative Policy

3 December 2024 CTF Roundtable Q. 5, 2024-1038171C6 - EIFEL and ATI Calculation where Taxpayer has Non-Capital Losses

Is the computation of “adjusted taxable income” (ATI), defined in s. 18.2(1), iterative if a taxpayer wishes to claim sufficient non-capital...

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B

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

No addback of terminal losses (p. 21)

Variable B of the ATI formula should include an addback for any terminal loss deduction under s. 20(16)...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (b)		222
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		90
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		92
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iv)		213
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		323
Tax Topics - Income Tax Act - Section 80 - Subsection 80(3)		44
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		260
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (e)		194

Paragraph (a)

Articles

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

Interest that is expressly permitted to be capitalized to resource pools is not added back (p. 4)

Variable B adds back a number of amounts so as...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(12)		156
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		104
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (b)		121
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a.1)		173
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		79
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(3)		194

Paragraph (h)

Articles

Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper

Potential iterative calculation where additional non-capital loss of another taxation year is used to offset additional taxable income arising...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		161
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		106
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		222
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(E)		164
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Exempt Interest And Financing Expenses		89

Joint Committee, "Summaries of Feedback on the EIFEL Administration", 2 November 2024 Joint Committee Submission to the CRA International and Large Business Directorate

Iterative calculation of ATI where non-capital losses are used (p. 5)

The calculation and application of non-capital losses where the EIFEL...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Ultimate Parent		92
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Relevant Period		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Cumulative Unused Excess Capacity		51

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022

Potential need to determine pre-EIFEL IFR and IFE (p. 7)

Given the potential to carry forward losses from pre-EIFEL years, taxpayers may be...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		117
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		37
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		97
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings - Paragraph (b)		37
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		63
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		100
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2) - Paragraph 18.21(2)(a)		53
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Group Ratio		28

C

Paragraph (a)

Articles

Joint Committee, "Summary of Feedback on Various Technical Issues", 14 April 2025 Joint Committee Submission

Upstream loan to a related Canadian corporation that is subject to Pt. XIII tax (pp. 5-7)

Where a foreign affiliate makes an upstream loan to its...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		38
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(b)		116
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c)		309
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Tax-Indifferent - Paragraph (c)		115
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Lease		63
Tax Topics - Income Tax Act - Section 191.1 - Subsection 191.1(1) - Excluded Dividend		69
Tax Topics - Income Tax Act - Section 12 - Subsection 12(13) - Paragraph 12(13)(b)		178
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(1) - Substantive Debt - Paragraph (c)		152
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(2)		132
Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(e) - Subparagraph 55(5)(e)(i)		157
Tax Topics - Income Tax Act - Section 93.4 - Subsection 93.4(1) - Foreign Accrual Business Income		53
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.2)		34

Paragraph (b)

Articles

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

Circularity issue arising from the FTCs being affected by deductible interest and financing expenses (IFE), which cannot be determined until the...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(12)		156
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		104
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (a)		140
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a.1)		173
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		79
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(3)		194

Paragraph (e)

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Need to properly flow through trust attributes to corporate or trust beneficiaries (pp. 24-26)

Para. (e) of variable C reduces ATI by an amount...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (b)		222
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		90
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		92
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iv)		213
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		323
Tax Topics - Income Tax Act - Section 80 - Subsection 80(3)		44
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		260
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B		212

Cumulative Unused Excess Capacity

Articles

Joint Committee, "Summaries of Feedback on the EIFEL Administration", 2 November 2024 Joint Committee Submission to the CRA International and Large Business Directorate

Recognition of CUEC when becoming subject to EIFEL (pp. 3-4)

Schedule 130 should accommodate taxpayers that become subject to the EIFEL rules...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Ultimate Parent		92
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Relevant Period		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		373

Eligible Group Entity

Articles

Josh Jones, Jeffrey Love, "Recent Developments in Asset Management", draft 2023 CTF Annual Conference paper

Eligible group entity status in bank-controlled ETF group (pp. 31-32)

In the scenario where the asset manager for a mutual fund corporation (MFC)...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 132 - Subsection 132(5.3) - Paragraph 132(5.3)(b)		100
Tax Topics - Income Tax Act - Section 104 - Subsection 104(7.1)		75
Tax Topics - Income Tax Act - Section 132 - Subsection 132(5.3) - Paragraph 132(5.3)(a)		141
Tax Topics - Income Tax Act - Section 132 - Subsection 132(4) - Capital Gains Redemption		106
Tax Topics - Income Tax Act - Section 132 - Subsection 132(5.31)		377
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(2) - Paragraph 251.2(2)(b)		133
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(1) - Investment Fund		354
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c)		250
Tax Topics - Income Tax Act - Section 94 - Subsection 94(1) - Fixed Interest		72
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income		241

Paragraph (a)

Articles

Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter

Relatedness by virtue of sibling status (p. 3)

As siblings may (and often will) have limited knowledge of each other’s business affairs, they...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		207
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		243
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Revenues		123
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		119
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A - D - Paragraph D(a)		70

Excess Capacity

Articles

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Application of RIFE first (p. 30)

A taxpayer’s excess capacity (generally arising where the maximum amount a taxpayer is permitted to deduct in...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		138
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii) - Clause (c)(iii)(A)		94
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(9)		143
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues - Paragraph (g)		101
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		42
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		51

Excluded Entity

Articles

Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper

Tainting of excluded entity status by individuals (pp. 2-7)

The inclusion in eligible group entities of resident corporations or trusts that are...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		126
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		106
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		222
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(E)		164
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Exempt Interest And Financing Expenses		89

Balaji Katlai, Hugh Neilson, "Canadian Inbound Investment: The EIFEL Trap?", International Tax Highlights (IFA Canada), Vol. 1, No. 2, August 2022, p. 7

25% threshold re non-resident equity rights (pp. 7-8)

From the perspective of a Canadian-controlled private corporation (CCPC) that has an active...

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PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Low de minimis threshold

The “excluded entity” definition in draft s. 18.2(1), which includes groups of corporations and trusts whose...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(2)		77
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		96
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Expenses - A - Paragraph (d)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(3)		113
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		73
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Acceptable Accounting Standards		85
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		66
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4) - Paragraph 18.2(4)(c)		104

Paragraph (b)

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Other countries use higher and flexible safe harbour limits (pp. 7-8)

The de minimis exception in para. (a) for a taxpayer which, together with...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		90
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		92
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iv)		213
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		323
Tax Topics - Income Tax Act - Section 80 - Subsection 80(3)		44
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		260
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B		212
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (e)		194

Paragraph (c)

Articles

Joint Committee, "Summary of Feedback on Various Technical Issues", 14 April 2025 Joint Committee Submission

Broad scope of eligible group entity (p. 3-4)

By including all related and affiliated persons, subject to limited exceptions, in the definition...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		38
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(b)		116
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Tax-Indifferent - Paragraph (c)		115
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (a)		269
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Lease		63
Tax Topics - Income Tax Act - Section 191.1 - Subsection 191.1(1) - Excluded Dividend		69
Tax Topics - Income Tax Act - Section 12 - Subsection 12(13) - Paragraph 12(13)(b)		178
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(1) - Substantive Debt - Paragraph (c)		152
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(2)		132
Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(e) - Subparagraph 55(5)(e)(i)		157
Tax Topics - Income Tax Act - Section 93.4 - Subsection 93.4(1) - Foreign Accrual Business Income		53
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.2)		34

Josh Jones, Jeffrey Love, "Recent Developments in Asset Management", draft 2023 CTF Annual Conference paper

Timing of applying tests under ss. (c)(ii) to (iv) (p. 30)

Although ss. (c)(ii) and (iii) do not expressly address when eligible entity status is...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 132 - Subsection 132(5.3) - Paragraph 132(5.3)(b)		100
Tax Topics - Income Tax Act - Section 104 - Subsection 104(7.1)		75
Tax Topics - Income Tax Act - Section 132 - Subsection 132(5.3) - Paragraph 132(5.3)(a)		141
Tax Topics - Income Tax Act - Section 132 - Subsection 132(4) - Capital Gains Redemption		106
Tax Topics - Income Tax Act - Section 132 - Subsection 132(5.31)		377
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(2) - Paragraph 251.2(2)(b)		133
Tax Topics - Income Tax Act - Section 251.2 - Subsection 251.2(1) - Investment Fund		354
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Eligible Group Entity		192
Tax Topics - Income Tax Act - Section 94 - Subsection 94(1) - Fixed Interest		72
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income		241

Subparagraph (c)(i)

Administrative Policy

3 December 2024 CTF Roundtable Q. 4, 2024-1038161C6 - EIFEL and the Excluded Entity Exception

Among the requirements in para. (c) of the definition of “excluded entity” in s. 18.2 is that “all or substantially all of the businesses...

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Words and Phrases

substantially all

Articles

Tax Technical Committee of STEP Canada, "Technical Interpretation Request Relating to EIFEL and Cross-Border Trust Holding Foreign Personal Use Property", STEP Canada Technical Interpretation Request

Background

Mr. X owned and controlled several substantial Canadian real estate corporations (RECs) and also settled a trust, of which he was the...

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Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Entity-by-entity application of test (p.9)

The test of all or substantially all of the businesses, undertakings and activities of each eligible...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		138
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii) - Clause (c)(iii)(A)		94
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(9)		143
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues - Paragraph (g)		101
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excess Capacity		137
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		42
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		51

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

“Substantially all” test must be satisfied for each business (p. 9)

All or substantially all of “each” business of the taxpayer and of...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (b)		222
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		92
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iv)		213
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		323
Tax Topics - Income Tax Act - Section 80 - Subsection 80(3)		44
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		260
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B		212
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (e)		194

Subparagraph (c)(ii)

Articles

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Exceeding of $5M threshold even where small FA interest or stacking of FAs (p. 9)

The test of the total fair market value of all property of a...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii) - Clause (c)(iii)(A)		94
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(9)		143
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues - Paragraph (g)		101
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excess Capacity		137
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		42
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		51

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Exclusion for FAs even with nominal income (pp. 9-10)

The exclusion for any foreign affiliate could apply, for instance, to a dormant foreign...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (b)		222
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		90
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		92
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iv)		213
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		323
Tax Topics - Income Tax Act - Section 80 - Subsection 80(3)		44
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		260
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B		212
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (e)		194

Subparagraph (c)(iii)

Articles

Kyle A. Ross, Trent J. Blanchette, "Issues with the ‘Excluded Entity’ Exception to the EIFEL Rules", Tax for the Owner-Manager, Vol. 23, No. 4, October 2023, p. 4

The third condition in the “domestic exception” in para. (c) of the definition of excluded entity is essentially that (1) no non-resident...

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Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter

Arbitrary nature of the (c)(iii) tests (pp. 4-5)

The s. (c)(iii) requirements for the “domestic” exception can cause an entity to qualify or...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		207
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		243
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Revenues		123
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Eligible Group Entity - Paragraph (a)		107
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A - D - Paragraph D(a)		70

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Reason for specified shareholder exclusion (p. 10)

It is understood that the policy concern being addressed arises where interest or financing...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (b)		222
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		90
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iv)		213
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		323
Tax Topics - Income Tax Act - Section 80 - Subsection 80(3)		44
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		260
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B		212
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (e)		194

Clause (c)(iii)(A)

Articles

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Likely requirement to hold a share (pp. 10-11)

Presumably the position in 2019-0798831C6, that a person must own at least one share of a...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		138
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(9)		143
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues - Paragraph (g)		101
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excess Capacity		137
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		42
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		51

Subparagraph (c)(iv)

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Exclusion for Canadian tax exempts, difficulties for publicly traded debt and level of aggregation (pp. 10-12)

Regarding the requirement that all...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (b)		222
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		90
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		92
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		323
Tax Topics - Income Tax Act - Section 80 - Subsection 80(3)		44
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		260
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B		212
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (e)		194

Excluded Interest

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Restriction to corps (pp. 14-16)

The excluded interest provision should be expanded to apply where either or both of the parties to a loan are...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (b)		222
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		90
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		92
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iv)		213
Tax Topics - Income Tax Act - Section 80 - Subsection 80(3)		44
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		260
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B		212
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (e)		194

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

Exclusion of excluded interest from interest and financing revenues/expenses (IFR/IFE) accommodates loss consolidations (p .4)

Excluded interest...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(12)		156
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (a)		140
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (b)		121
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a.1)		173
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		79
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(3)		194

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

General scope of excluded interest rules

The “excluded interest” rules depart from the 2021 federal budget proposals (which stated that...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(2)		77
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		96
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Expenses - A - Paragraph (d)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(3)		113
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Acceptable Accounting Standards		85
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		66
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4) - Paragraph 18.2(4)(c)		104

Excluded Lease

Articles

Joint Committee, "Summary of Feedback on Various Technical Issues", 14 April 2025 Joint Committee Submission

Excluded lease definition re a building should extend to the related land (p. 7)

An excluded lease would include for instance the lease of...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		38
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(b)		116
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c)		309
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Tax-Indifferent - Paragraph (c)		115
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (a)		269
Tax Topics - Income Tax Act - Section 191.1 - Subsection 191.1(1) - Excluded Dividend		69
Tax Topics - Income Tax Act - Section 12 - Subsection 12(13) - Paragraph 12(13)(b)		178
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(1) - Substantive Debt - Paragraph (c)		152
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(2)		132
Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(e) - Subparagraph 55(5)(e)(i)		157
Tax Topics - Income Tax Act - Section 93.4 - Subsection 93.4(1) - Foreign Accrual Business Income		53
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.2)		34

Exempt Interest And Financing Expenses

Articles

Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper

Allocation of financing to purpose-built residential rental (pp. 18-19)

The proposed definition of “exempt interest and financing expenses”...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		161
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		126
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		106
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		222
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(E)		164
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		39

Interest and Financing Expenses

A

Paragraph (d)

Articles

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Potential inclusion of amounts under derivatives

The definitions of interest and financing expenses and revenues, as supplemented by the...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(2)		77
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		96
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(3)		113
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		73
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Acceptable Accounting Standards		85
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		66
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4) - Paragraph 18.2(4)(c)		104

Interest and Financing Revenues

Articles

Joint Committee, "Summary of Feedback on Various Technical Issues", 14 April 2025 Joint Committee Submission

IFR should include s. 78(1)(a) inclusion (p.2)

For greater certainty, an amount included in a taxpayer's income under s. 78(1)(a) should be...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(b)		116
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c)		309
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Tax-Indifferent - Paragraph (c)		115
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (a)		269
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Lease		63
Tax Topics - Income Tax Act - Section 191.1 - Subsection 191.1(1) - Excluded Dividend		69
Tax Topics - Income Tax Act - Section 12 - Subsection 12(13) - Paragraph 12(13)(b)		178
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(1) - Substantive Debt - Paragraph (c)		152
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(2)		132
Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(e) - Subparagraph 55(5)(e)(i)		157
Tax Topics - Income Tax Act - Section 93.4 - Subsection 93.4(1) - Foreign Accrual Business Income		53
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.2)		34

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022

Various imputed amounts not included (p.6)

The IFR definition will not be amended to include amounts under ss. 16.1, 17 and 247(2), and draft...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		117
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		37
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		97
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings - Paragraph (b)		37
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		100
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2) - Paragraph 18.21(2)(a)		53
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Group Ratio		28

Paragraph (g)

Articles

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Reduction for FAT claims in future years (p. 20)

The inclusion under para. (g) of the interest and financing revenues definition of the relevant...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		138
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii) - Clause (c)(iii)(A)		94
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(9)		143
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excess Capacity		137
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		42
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		51

Relevant Affiliate Interest And Financing Expenses

Articles

Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper

Potential inclusion in RAIFE of capital losses from excluded property (p. 11)

Notwithstanding the Explanatory Notes’ statement that the...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		161
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		126
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		222
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(E)		164
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Exempt Interest And Financing Expenses		89

Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter

No RAIFE carve-out for ss. 95(2)(a) and 95(2)(a)(ii)(D) amounts (p. 14)

A controlled foreign affiliate’s interest and financing expenses...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		243
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Revenues		123
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Eligible Group Entity - Paragraph (a)		107
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		119
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A - D - Paragraph D(a)		70

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022

Separate flow-up of relevant affiliate IFE or relevant affiliate IFR (p. 4)

The amounts that would be the interest and financing revenues (IFRs)...

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Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		37
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		97
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings - Paragraph (b)		37
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		63
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		100
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2) - Paragraph 18.21(2)(a)		53
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Group Ratio		28

Relevant Affiliate Interest And Financing Revenues

Articles

Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter

Inappropriate reduction of RAIFR for s. 91(4) deduction for Canadian withholding tax

It is inappropriate to reduce the relevant affiliate...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		207
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		243
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Eligible Group Entity - Paragraph (a)		107
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii)		119
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A - D - Paragraph D(a)		70

Specified Pre-Regime Loss

Administrative Policy

CRA Webpage, “Excessive interest and financing expenses limitation rules,” 24 September 2024

Election may be useful where the taxpayer has no documentary support for IFE

Specified pre-regime loss election

If you are deducting a non-capital...

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(18)		626
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		484
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(6)		82
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(E)		72

Tax-Indifferent

Paragraph (c)

Articles

Joint Committee, "Summary of Feedback on Various Technical Issues", 14 April 2025 Joint Committee Submission

REIT as tax-indifferent (pp. 4-5)

The definition of “tax-indifferent” includes a trust resident in Canada if more than 50% of the fair market...

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		38
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(b)		116
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c)		309
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (a)		269
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Lease		63
Tax Topics - Income Tax Act - Section 191.1 - Subsection 191.1(1) - Excluded Dividend		69
Tax Topics - Income Tax Act - Section 12 - Subsection 12(13) - Paragraph 12(13)(b)		178
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(1) - Substantive Debt - Paragraph (c)		152
Tax Topics - Income Tax Act - Section 183.3 - Subsection 183.3(2)		132
Tax Topics - Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(e) - Subparagraph 55(5)(e)(i)		157
Tax Topics - Income Tax Act - Section 93.4 - Subsection 93.4(1) - Foreign Accrual Business Income		53
Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.2)		34

Subsection 18.2(2)

Articles

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Unclear whether s. 18.2 applies to computing FAPI

It is unclear whether the rules apply to computing the income of a foreign affiliate, which is...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		96
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Expenses - A - Paragraph (d)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(3)		113
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		73
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Acceptable Accounting Standards		85
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		66
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4) - Paragraph 18.2(4)(c)		104

John Unger, "Proposed Section 18.2: Limitations on Deducting Costs to Finance Foreign Affiliates", International Tax, CCH, December 2007, No. 37.

Subsection 18.2(3)

Administrative Policy

2008 IFA Round Table, Q. 10.

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)		0

Articles

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Effect of increasing future recapture

Draft s. 18.2(3) deems amounts of previously capitalized interest that are otherwise deductible as CCA or...

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(2)		77
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		96
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Expenses - A - Paragraph (d)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		73
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Acceptable Accounting Standards		85
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		66
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4) - Paragraph 18.2(4)(c)		104

Subsection 18.2(4)

Administrative Policy

CRA Webpage, “Excessive interest and financing expenses limitation rules,” 24 September 2024

Form of filing EIFEL elections before election forms are available

Election forms

The CRA is preparing forms that will allow you to apply for...

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(18)		626
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(6)		82
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Specified Pre-Regime Loss		130
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(E)		72

Articles

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Requirement for accuracy (p. 34)

Any over-designation, including an immaterial one, will invalidate a transfer of excess capacity under s....

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		138
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii) - Clause (c)(iii)(A)		94
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(9)		143
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues - Paragraph (g)		101
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excess Capacity		137
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		51

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022

Transferee can have a different functional currency or be a REIT (p. 7)

The EIFEL revisions have removed the requirement that cumulative unused...

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		117
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		37
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		97
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings - Paragraph (b)		37
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		63
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		55
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2) - Paragraph 18.21(2)(a)		53
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Group Ratio		28

Paragraph 18.2(4)(c)

Articles

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Difficulties for consolidated operation of financial services groups

S. 18.2(4)(c), which effectively prevents a “relevant financial...

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(2)		77
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		96
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Expenses - A - Paragraph (d)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(3)		113
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		73
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Acceptable Accounting Standards		85
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		66

Subsection 18.2(6)

Administrative Policy

CRA Webpage, “Excessive interest and financing expenses limitation rules,” 24 September 2024

Waiver of requirement for transferee to file an information return

Information return requirement waived

If you have received capacity in a joint...

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(18)		626
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		484
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Specified Pre-Regime Loss		130
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(E)		72

Subsection 18.2(9)

Articles

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Application where share sale but not asset sale (pp. 11-12)

Where, for example, a Canadian-resident taxpayer has a subsidiary that causes it to...

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		138
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii) - Clause (c)(iii)(A)		94
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues - Paragraph (g)		101
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excess Capacity		137
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		42
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		51

Subsection 18.2(12)

Articles

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

Effective 30% capacity generated by interest and financing revenues (IFR) from NAL non-resident – even if paid by its Cdn. branch (p. 3)

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		104
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (a)		140
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (b)		121
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a.1)		173
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		79
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(3)		194

Subsection 18.2(18)

Administrative Policy

CRA Webpage, “Excessive interest and financing expenses limitation rules,” 24 September 2024

Information required to be filed with return

Filing your information

You must report your information relating to the rules on the Schedule 130...

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		484
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(6)		82
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Specified Pre-Regime Loss		130
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(E)		72

You are here

Section 18.2

Table of Contents

Subsection 18.2(1)

Adjusted Taxable Income

Articles

Josh Jones, Jeffrey Love, "Recent Developments in Asset Management", draft 2023 CTF Annual Conference paper

A

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

D

Paragraph D(a)

Articles

Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter

Paragraph D(b)

Administrative Policy

3 December 2024 CTF Roundtable Q. 5, 2024-1038171C6 - EIFEL and ATI Calculation where Taxpayer has Non-Capital Losses

B

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Paragraph (a)

Articles

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

Paragraph (h)

Articles

Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper

Joint Committee, "Summaries of Feedback on the EIFEL Administration", 2 November 2024 Joint Committee Submission to the CRA International and Large Business Directorate

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022

C

Paragraph (a)

Articles

Joint Committee, "Summary of Feedback on Various Technical Issues", 14 April 2025 Joint Committee Submission

Paragraph (b)

Articles

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

Paragraph (e)

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Cumulative Unused Excess Capacity

Articles

Joint Committee, "Summaries of Feedback on the EIFEL Administration", 2 November 2024 Joint Committee Submission to the CRA International and Large Business Directorate

Eligible Group Entity

Articles

Josh Jones, Jeffrey Love, "Recent Developments in Asset Management", draft 2023 CTF Annual Conference paper

Paragraph (a)

Articles

Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter

Excess Capacity

Articles

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Excluded Entity

Articles

Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper

Balaji Katlai, Hugh Neilson, "Canadian Inbound Investment: The EIFEL Trap?", International Tax Highlights (IFA Canada), Vol. 1, No. 2, August 2022, p. 7

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Paragraph (b)

Articles

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Paragraph (c)

Articles

Joint Committee, "Summary of Feedback on Various Technical Issues", 14 April 2025 Joint Committee Submission

Josh Jones, Jeffrey Love, "Recent Developments in Asset Management", draft 2023 CTF Annual Conference paper

Subparagraph (c)(i)

Administrative Policy

3 December 2024 CTF Roundtable Q. 4, 2024-1038161C6 - EIFEL and the Excluded Entity Exception

Articles

Tax Technical Committee of STEP Canada, "Technical Interpretation Request Relating to EIFEL and Cross-Border Trust Holding Foreign Personal Use Property", STEP Canada Technical Interpretation Request

Background

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Subparagraph (c)(ii)

Articles

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee

Subparagraph (c)(iii)

Articles

Kyle A. Ross, Trent J. Blanchette, "Issues with the ‘Excluded Entity’ Exception to the EIFEL Rules", Tax for the Owner-Manager, Vol. 23, No. 4, October 2023, p. 4

Joint Committee, "Summary of Issues Raised with the Department of Finance in Respect of the Excessive Interest and Financing Expenses Limitation (EIFEL) Proposals", 22 March 2023 Joint Committee letter

Joint Committee, "Excessive Interest and Financing Expenses Limitation Proposals", 5 May 2022 Submission of the Joint Committee