Cases
Bowater Canadian Ltd. v. The Queen, 87 DTC 5287, [1987] 2 CTC 47 (FCA)
As a condition to the sale of a company ("Bulkley") in which the taxpayer and another corporation ("Bathurst") had substantial loan and share...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | interest incurred to acquired defaulted debt | 163 |
The Queen v. Lehndorff Realty Developments Ltd., 86 DTC 6610, [1987] 1 CTC 42 (FCTD)
A German limited partnership ("Canada Grund") having control of the taxpayer, in consideration of the taxpayer's promise to indemnify it from...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 172 - Subsection 172(1) | 35 |
Isaac Meisels Investments Ltd. v. The Queen, 85 DTC 5029, [1985] 1 CTC 9 (FCTD)
Non-interest bearing advances to a subsidiary of the taxpayer were not made for the purpose of earning income.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss | 58 |
The Queen v. Merban Capital Corp. Ltd., 85 DTC 5014, [1985] 1 CTC 1 (FCTD), rev'd 89 DTC 5404 (FCA)
The taxpayer guaranteed the obligations of its subsidiary ("MKH") and a subsidiary in turn of MKH ("Holdings") to pay interest on bank loans...
Brunette Investments Ltd. v. The Queen, 81 DTC 5367, [1981] CTC 486 (FCTD)
An "administration fee" charged by a management company ("WP") to the taxpayer represented the amount of an advance that WP had made to an...
The Queen v. Doral Investment Corp., 79 DTC 5316, [1979] CTC 398 (FCTD)
The Court rejected an argument that a non-interest bearing loan was made by the taxpayer company to a second company ("East End") in order to earn...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) | non-interest bearing loan | 42 |
The Queen v. Laidlaw Transport Ltd., 77 DTC 5091, [1977] CTC 151 (FCTD)
A fee of $61,317 which a subsidiary paid to its parent for services that the parent (primarily in the person of its shareholder and officer)...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 245 - Old | 101 |
Montreal Coke and Manufacturing Co. v. MNR, [1944] A.C. 126, [1944] CTC 94 (P.C.)
Expenses incurred by the taxpayers in redeeming outstanding bonds before maturity and reborrowing at lower rates of interest, including redemption...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures | refinancing fees not incurred in the course of earning income | 163 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | 95 |
Administrative Policy
14 June 2017 External T.I. 2016-0666411E5 - Negative returns on investments
The interest rate on deposits held with a financial institution fluctuates during the year so that in some months, positive interest accrues and...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | capital loss on loan with nil interest rate may be denied by s. 40(2)(g)(ii) | 119 |
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | negative interest not a contra to positive interest | 150 |