Subsection 20.1(1) - Borrowed money used to earn income from property
Administrative Policy
S3-F6-C1 - Interest Deductibility
Disappearing source rules
1.41 In general terms, the disappearing source rules in section 20.1 apply where borrowed money ceases to be used for...
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...
| 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...
14 June 2001 External T.I. 2001-0080085 F - Intérêt payé pour honorer une caution
An individual borrowed money in order to honour his guarantee of debts of a small business corporation that he owned and which had become...
14 March 2000 External T.I. 1999-0007475 F - REMISE DE DETTE
A taxpayer borrows $3,000 from one person and $1,000 from another to acquire shares at a cost of $5,000. Subsequently, the value of the shares...
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...
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...
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...
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...