Financing Expenditures

Cases

Imperial Oil Ltd. v. Canada, 2004 DTC 6702, 2004 FCA 361, rev'd 2006 SCC 46

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Gifford v. Canada, 2004 DTC 6120, 2004 SCC 15, [2004] 1 S.C.R. 411

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Bowater Mersey Paper Co. Ltd. v. The Queen, 86 DTC 6293, [1986] 1 CTC 240 (FCTD), rev'd 87 DTC 5382, [1987] 2 CTC 159 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 165 - Subsection 165(7) 42

Emerson v. The Queen, 85 DTC 5236, [1985] 1 CTC 324 (FCTD), aff'd 86 DTC 6184, [1986] 1 CTC 422 (FCA)

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The Queen v. Marchand, 78 DTC 6507, [1978] CTC 763 (FCTD), aff'd [1979] CTC xvii (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Accounting Principles 52

Canada Permanent Mortgage Corp. v. MNR, 71 DTC 5409 (FCTD)

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Silverman v. MNR, 60 DTC 1212, [1960] CTC 262 (Ex Ct)

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Canada Safeway Ltd. V. Minister of National Revenue, 57 DTC 1239, [1957] CTC 335, [1957] S.C.R. 717

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Stock Exchange Building Corp. Ltd. v. Minister of National Revenue, [1955] S.C.R. 235, 55 DTC 1014, [1955] CTC 5

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Bennett and White v. The King, 49 DTC 514, [1949] CTC 1, [1949] S.C.R. 287

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Montreal Coke and Manufacturing Co. v. MNR, [1944] A.C. 126, [1944] CTC 94 (P.C.)

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See Also

A.P. Toldo Holding Corporation v. The Queen, 2014 DTC 1042 [at 2787], 2013 TCC 416

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Words and Phrases
money-lending business
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) no retained earnings or stated capital 195

Wescast Industries Inc. v. The Queen, 2010 DTC 1364 [at 4432], 2010 TCC 538

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SPG International Ltée v. The Queen, 98 DTC 1093 (TCC)

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Wharf Properties Ltd. v. Commissioner of Inland Revenue (Hong Kong), [1997] BTC 173 (PC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A wages part of cost 40

Anderson v. MNR, 92 DTC 1778 (TCC)

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MNR v. Peninsular Investments Ltd., 63 DTC 1149 (Ex Ct)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 133 - Subsection 133(1) 168

Scottish North American Trust, Ltd. v. Farmer (1911), 5 TC 693 (HL)

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Gresham Life Insurance Society v. Styles (1892), 3 TC 185 (HL)

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Administrative Policy

9 December 2013 External T.I. 2013-0507931E5 F - Financing fees

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) annual internal cash pool utilization fees likely are deductible under s. 20(1)(e.1) 241
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) cash pool utilization fees could be deductible under s. 20(1)(e) 192

19 September 2008 Internal T.I. 2008-0272441I7 - GUILT LOCK DERIVATIVE

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2003 TEI Roundtable Q. 13, 2003-004856 -

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1 March 2001 External T.I. 2001-006871 -

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Revenue Canada Round Table TEI, 16 May 1994, Q. 14 (C.T.O "Assumption of Debt")

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13 January 1993 T.I. 922191 (November 1993 Access Letter, p. 500, ¶C76-077)

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93 C.P.T.J. - Q.36

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92 C.M.TC - Q.4

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10 July 1991 Decision Summary (Tax Window, No. 5, p. 2, ¶1345)

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10 May 1990 T.I. (October 1990 Access Letter, ¶1455)

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23 February 1990 T.I. (July 1990 Access Letter, ¶1317)

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14 December 89 T.I. (May 1990 Access Letter, ¶1201)

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ATR-4 (29 Nov. 85)

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81 C.R. - Q.46

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80 C.R. - Q.35

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IT-104R "Deductibility of Fines or Penalties"

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Articles

Ewens, "Proposed Amendments Affecting Debt and Equity Reorganizations", 1993 Canadian Petroleum Tax Journal, Vol. 6, No. 1, p. 49

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