Section 20.1

Subsection 20.1(1) - Borrowed money used to earn income from property

Administrative Policy

3 June 2003 Internal T.I. 2003-0181487 F - DEDUCTIBILITE DES INTERETS GARANTIE

An individual was required to guarantee a long to a corporation wholly-owned by him and then, three years later, the corporation ceased to carry...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) guarantee of wholly-owned corporation’s debt given for income-producing purpose is satisfied with borrowed money on which interest may be deductible 206

17 April 2003 Internal T.I. 2003-0006407 F - PRET SANS INTERET DEDUCTIBILITY INTERETS

An interest-free loan is made to a corporation which, two years’ later, becomes bankrupt. After noting that under its application of the...

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10 June 1996 External T.I. 9611135 - LOSS OF SOURCE INTEREST DEDUCTIBILITY

Where a partnership is dissolved and the partners receive real property from the partnership in satisfaction of their partnership interests, and...

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18 July 1995 Internal T.I. 9508157 - LOSS OF SOURCE

Interest paid by an individual on a loan made to honour a guarantee made by the individual of borrowings made by a Canadian-controlled private...

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8 December 1994 External T.I. 9422085

"Where an amount is deemed by virtue of section 80.5 of the Act, to be interest paid in respect of the year pursuant to a legal obligation to pay...

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Articles

Chang, Briant, "Interest Deductibility: New Loss of Source of Income Rules", 1995 Canadian Tax Journal, Vol. 43, No. 1, p. 154.

Subsection 20.1(2)

Paragraph 20.1(2)(c)

See Also

Moras v. The Queen, 2019 TCC 111 (Informal Procedure)

Prior to the transfer of his accountancy practice in 2007 to his corporation, the taxpayer borrowed under a home equity line of credit (in the...

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