Paragraph 20(1)(c)

Cases

TDL Group Co. v. Canada, 2016 FCA 67

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Swirsky v. Canada, 2014 DTC 5037 [at 6723], 2014 FCA 36, aff'g 2013 TCC 73, 2013 DTC 1078 [at 431]

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention no objectively reasonable income-producing purpose 83
Tax Topics - General Concepts - Onus applying GAAR at confirmation stage doesn't shift onus 63

Collins v. Canada, 2010 DTC 5028 [at 6625], 2010 FCA 12

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Scragg v. Canada, 2009 DTC 6024, 2009 FCA 180

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Novopharm Ltd. v. Canada, 2003 DTC 5195, 2003 FCA 112

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Stewart v. Canada, 2002 DTC 6969, 2002 SCC 46, [2002] 2 S.C.R. 645

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Canada v. Canadian Helicopters Ltd., 2002 DTC 6805, 2002 FCA 30

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 106

Dansereau v. The Queen, 2001 DTC 5642, 2001 FCA 305

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Singleton v. Canada, 2001 DTC 5533, 2001 SCC 61, [2001] 2 S.C.R. 1046

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Tax Topics - General Concepts - Tax Avoidance 43

Ludco Enterprises Ltd. v. Canada, 2001 DTC 5505, [2001] 2 S.C.R. 1082, 2001 SCC 62

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention objective and subjective manifestations of purpose 98
Tax Topics - General Concepts - Tax Avoidance right to structure for tax avoidance 121
Tax Topics - Statutory Interpretation - Certainty 97

Canada v. Milewski, 2000 DTC 6559 (FCA)

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Chase Manhattan Bank of Canada v. Canada, 2000 DTC 6018 (FCA)

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Shell Canada Ltd. v. Canada, 99 DTC 5669, [1999] 3 S.C.R. 622

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Substance legal relationships prevail over economic realities 193
Tax Topics - General Concepts - Tax Avoidance taxpayes entitled to rely on structure of their transactions 152
Tax Topics - Income Tax Act - Section 67 90
Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange FX hedging gain was capital gain as hedged borrowing was on capital account 217
Tax Topics - Statutory Interpretation - Specific v. General Provisions 90

Singleton v. The Queen, 99 DTC 5362 (FCA), aff'd supra.

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Hudson Bay Mining & Smelting Co. Ltd. v. The Queen, 99 DTC 5269 (FCA)

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Ludco Enterprises Ltd. v. The Queen, 99 DTC 5153 (FCA), aff'd supra

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Elmridge Country Club Inc. v. The Queen, 99 DTC 5127 (FCA)

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Tax Topics - Income Tax Act - Section 149 - Subsection 149(5) 43

Laliberté v. Canada, 98 DTC 6604 (FCA)

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The Queen v. Sherway Centre Ltd., 98 DTC 6121 (FCA)

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Parthenon Investments Ltd. v. Canada (National Revenue), 97 DTC 5343 (FCA)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation control means ultimate control 133

74712 Alberta Ltd. (formerly Cal-Gas & Equipment Ltd.) v. The Queen, 97 DTC 5126 (FCA)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Purpose/Intention 51

Brill v. The Queen, 96 DTC 6572 (FCA)

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Tennant v. M.N.R., 96 DTC 6121, [1996] 1 S.C.R. 305

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Tax Topics - Statutory Interpretation - Reciprocity 64

Riddell v. The Queen, 95 DTC 5526 (FCTD)

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Farn v. The Queen, 95 DTC 5426 (FCTD)

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Canassurance, Compagnie d'Assurance-Vie Inc. v. The Queen, 94 DTC 6186 (FCA)

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The Queen v. Mandryk, 92 DTC 6329 (FCA)

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Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss guarantee made qua shareholder 102

Bowes v. The Queen, 91 D.T.C 5310 (FCTD)

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Tax Topics - General Concepts - Evidence 48

Livingston International Inc. v. The Queen, 91 DTC 5066 (FCTD), aff'd 92 DTC 6197 (FCA)

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Haro Pacific Enterprises Ltd. v. The Queen, 90 DTC 6583 (FCTD)

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Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) capital distribution part of consideration for land contribution 145

The Queen v. Attaie, 90 DTC 6413 (FCA)

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Kalthoff v. The Queen, 90 DTC 6378 (FCTD), aff'd 92 DTC 6001 (FCA)

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The Queen v. Malik, 89 DTC 5141 (FCTD)

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Holotnak v. The Queen, 87 DTC 5443 (FCTD), aff'd 89 DTC 5527 (FCA)

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Bowater Canadian Ltd. v. The Queen, 87 DTC 5287, [1987] 2 CTC 47 (FCA)

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Bronfman Trust v. The Queen, [1987] 1 S.C.R. 32, 87 DTC 5059, [1987] 1 CTC 117

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Emerson v. The Queen, 86 DTC 6184, [1986] 1 CTC 422 (FCA)

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Toolsie v. The Queen, 86 DTC 6117, [1986] 1 CTC 216 (FCTD)

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The Queen v. Terra Mining & Exploration Ltd. (N.P.L.), 84 DTC 6185, [1984] CTC 176 (FCTD)

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Alberta and Southern Gas Co. Ltd. v. The Queen, 76 DTC 6362, [1976] CTC 639 (FCTD), aff'd 77 DTC 5244 [1977] CTC 388 (FCA), aff'd 78 DTC 6566, [1978] CTC 780, [1979] 1 S.C.R. 36

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The Queen v. Balmoral Holdings Ltd., 75 DTC 5296 (FCTD)

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Sternthal v. The Queen, 74 DTC 6646, [1974] CTC 851 (FCTD)

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Byke Estate v. The Queen, 74 DTC 6585, [1974] CTC 763 (FCTD)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 100

MNR v. Yonge-Eglinton Building Ltd., 74 DTC 6180, [1974] CTC 209 (FCA)

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Matheson v. The Queen, 74 DTC 6176, [1974] CTC 186 (FCTD)

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Lakeview Gardens Corp. v. MNR, 73 DTC 5437, [1973] CTC 586 (FCTD)

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MNR v. Mid-West Abrasive Co. of Canada Ltd., 73 DTC 5429, [1973] CTC 548 (FCTD)

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Words and Phrases
in respect of the year
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) indefinite payment arrangements for interest 74
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 74

McLaws v. Minister of National Revenue, 72 DTC 6149, [1972] CTC 165, [1974] S.C.R. 887

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Trans-Prairie Pipelines Ltd. v. MNR, 70 DTC 6351, [1970] CTC 537 (Ex Ct)

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D.W.S. Corp. v. MNR, 68 DTC 5045, [1968] CTC 65 (Ex Ct), briefly aff'd 69 DTC 5203 (SCC)

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Société Coopérative Agricole du Canton de Granby v. The Minister of National Revenue, 61 DTC 1205, [1961] CTC 326, [1961] S.C.R. 671

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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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Interior Breweries Ltd. v. MNR, 55 DTC 1090, [1955] CTC 143 (Ex Ct)

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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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Words and Phrases
borrowed capital

Minister of National Revenue v. McCool, 49 DTC 700, [1949] CTC 395, [1950] S.C.R. 80

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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

Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONSC 7286

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Words and Phrases
interest

R. v. Golini, 2016 TCC 174

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) a loan to a shareholder with recourse limited to an asset pledged by the corporation was a shareholder benefit 536
Tax Topics - General Concepts - Sham sham doctrine did not apply to a "minor pretence" 326
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) use of corporate asset to create PUC was abuse of s. 84(1) 244
Tax Topics - Income Tax Act - Section 84 - Subsection 84(1) policy of 84(1) 215

ENMAX Energy Corp. v. Alberta, 2016 ABQB 334

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Tax Topics - Income Tax Act - Section 67 Gabco test implies a range 110
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) arm's length comparables for intercompany interest rate not dispositive 284

Re Nortel Networks Corporation, 2015 ONCA 681

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The TDL Group Co. v. The Queen, 2015 DTC 1098 [at 567], 2015 TCC 60, rev'd supra.

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McLarty v. The Queen, 2014 DTC 1162 [at 3556], 2014 TCC 30

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Tax Topics - General Concepts - Agency participations contrary to agreement were disregarded 107
Tax Topics - General Concepts - Illegality participations contrary to agreement were disregarded 107
Tax Topics - General Concepts - Sham sham cannot apply to just part of transaction 139
Tax Topics - General Concepts - Tax Avoidance sham cannot apply to just part of transaction 139
Tax Topics - Income Tax Act - Section 67 leveraged purchase of seismic data at arm's length was presumptively reasonable 282

Doulis v. The Queen, 2014 DTC 1054 [at 2933], 2014 TCC 26 (Informal Procedure)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(t) tax arrears interest is not a business expense 82
Tax Topics - Income Tax Act - Section 9 - Interest Income tax arrears interest is not a business expense 82

Garber v. The Queen, 2014 DTC 1045 [at 2812], 2014 TCC 1

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

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Collins v. The Queen, 2009 DTC 286, 2009 TCC 56, rev'd supra

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Words and Phrases
payable

Estate of Mary Rizak c/o George Jehn v. The Queen, 2008 DTC 4460, 2008 TCC 434 (Informal Procedure)

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Tesainer v. The Queen, 2008 DTC 2807, 2008 TCC 101

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Lipson v. The Queen, 2006 DTC 2687, 2006 TCC 148, aff'd supra.

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Crown Forest Industries Ltd. v. The Queen, 2006 DTC 2321, 2006 TCC 47

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Stare Decisis 98

Moufarrège v. Quebec (Deputy Minister of Revenue), 2005 DTC 5605, [2005] 2 S.C.R. 598, 2005 SCC 53

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International Colin Energy Corp. v. The Queen, 2002 DTC 2185, 2002 CanLII 47015 (TCC)

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Hill v. The Queen, 2002 DTC 1749 (TCC)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt funds to support cheques 137
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) no Crown explanation of different treatment of simple interest 233

722540 Ontario Inc. v. The Queen, 2002 DTC 1307 (TCC)

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Penn Ventilator Canada Ltd. v. The Queen, 2002 DTC 1498 (TCC)

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Canada v. Confederation Life Insurance Co., [2001] OJ No. 2610 (Ont SCJ)

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Sudbrack v. The Queen, 2000 DTC 2521, Docket: 98-2386-IT-G (TCC)

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Dansereau v. The Queen, 2000 DTC 1559 (TCC) (Informal Procedure)

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Meggitt v. The Queen, 2000 DTC 1448 (TCC) (Informal Procedure)

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Gagnon v. The Queen, 99 DTC 845 (TCC)

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C.R.B. Logging Co. Ltd. v. The Queen, 99 DTC 840, 1998 CanLII 185 (TCC), aff'd , 2000 DTC 6547, Docket: A-242-99 (FCA)

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Lewisport Holdings v. The Queen, 99 DTC 253, 1998 CanLII 185 (TCC)

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Chisholm v. The Queen, 99 DTC 150 (TCC) (Informal Procedure)

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Aitchison v. The Queen, 98 DTC 1956 (TCC)

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Canadian Pacific Ltd. v. The Queen, docket 95-3534-IT-G (TCC)

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Mohammad v. The Queen, 97 DTC 5503 (FCA)

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Integrated Wood Research Inc. v. The Queen, 98 DTC 1258 (TCC)

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Robitaille v. The Queen, 97 DTC 1286 (TCC)

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Barbican Properties Inc. v. The Queen, 97 DTC 122 (TCC), briefly aff'd 97 DTC 5008 (FCA)

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WP Graphics Inc. v. The Queen, [1996] TCJ. No. 146 (TCC)

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Canwest Broadcasting Ltd. v. The Queen, 96 DTC 1375 (TCC)

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Redclay Holdings Ltd. v. The Queen, 96 DTC 1207 (TCC)

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Words and Phrases
payable
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 78 - Subsection 78(1) 81

Joy v. The Queen, 96 DTC 2026 (TCC)

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Vander Nurseries Inc. v. The Queen, 95 DTC 91 (TCC)

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Plawiuk v. The Queen, 94 DTC 1050 (TCC)

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Mutual Life Assurance Co. of Canada v. 837690 Ontario Ltd. (1993), 36 RPR (2d) 159 (Ont Ct J (GD))

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Spectron Computer Corp. v. MNR, 93 DTC 1473 (TCC)

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Mark Resources Inc. v. The Queen, 93 DTC 1004 (TCC)

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Words and Phrases
income
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 245 - Subsection 245(3) 98

Lessard v. MNR, 93 DTC 680 (TCC)

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Morscher v. MNR, 92 DTC 2214 (TCC)

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Words and Phrases
interest

Glass v. MNR, 92 DTC 1759 (TCC)

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Goulard v. MNR, 92 DTC 1244 (TCC)

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Brown v. The Queen, 92 DTC 1105 (TCC)

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Sutherland v. The Queen, 91 DTC 5318 (FCTD)

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Kornelow v. MNR, 91 DTC 431 (TCC)

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Tor-Guelph Holdings Ltd. v. MNR, 91 DTC 355 (TCC)

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Gruyich Services Inc. v. MNR, 91 DTC 159 (TCC)

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Dockman v. MNR, 90 DTC 1804 (TCC)

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Wilson v. MNR, 90 DTC 1744 (TCC)

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Lee v. MNR, 89 DTC 443 (TCC)

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Scott v. MNR, 89 DTC 218 (TCC)

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Bowes & Cocks Ltd. v. MNR, 89 DTC 341 (TCC)

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Wilson v. MNR, 88 DTC 1418 (TCC)

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Marine Management Ltd. v. Dep. Cmmer. of Inland Rev. (Fiji), [1986] BTC 184 (PC)

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Gilmour v. The Queen, 81 DTC 5322, [1981] CTC 401 (FCTD)

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Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) 143

Re Balaji Apartments Ltd. and Manufacturers Life Insurance Co. (1979), 100 DLR (3d) 695 (Ont HC)

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Re Euro Hotel (Belgravia) Ltd. (1975), 51 TC 293 (Ch D)

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Attorney General (Ontario) v. Barfried Enterprises, [1963] S.C.R. 570

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C.I.R. v. Pullman Car Co., Ltd. (1954), 35 TC 221 (Ch D)

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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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Words and Phrases
interest

Inland Revenue Commissioners v. Rowntree & Co. Ltd., [1948] 1 All ER 482 (CA)

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Reference as to the Validity of Section 6 of the Farm Security Act, 1944 of Saskatchewan, [1947] S.C.R. 394, aff'd [1949] AC 110

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Dupuis Frères Ltd. v. Minister of Customs and Excise (1927), 1 DTC 104 (Ex Ct)

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A. W. Walker & Co. v. C.I.R. (1920), 12 TC 297 (KBD)

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Administrative Policy

1 June 2016 External T.I. 2015-0601211E5 - Mortgage loan from RRSP to make a shareholder loan

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Tax Topics - Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j.1) use of qualified mortgage loan proceeds of no import 178
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (a) 4900(1)(j.1) insurance requirements generally arm's length/potential advantage on default 239
Tax Topics - Income Tax Act - Section 207.01 - Subsection 207.01(1) - RRSP Strip 4900(1)(j.1) mortgage loan unlikely to be acquired at less than FMV 217

29 January 2016 Internal T.I. 2015-0621401I7 - interest deductibility and share repurchases

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24 August 2015 External T.I. 2015-0589841E5 - Financial instrument as a debt obligation

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5 February 2016 Internal T.I. 2014-0555291I7 - Interest deductibility

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9 October 2015 APFF Roundtable Q. 11, 2015-0595771C6 F - Deductibility of interest in a leveraged buyout

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9 October 2015 APFF Financial Strategies and Financial Instruments Roundtable Q. 3, 2015-0588951C6 F - Deductibility of interest – ss. 20.1(1)

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11 September 2015 Internal T.I. 2015-0586301I7 - Premiums received on re-opening of debt

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Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital - Element E premium received on note re-opening subject to eligible capital amount treatment if not otherwise taxable 152

25 May 2015 External T.I. 2014-0563351E5 - Mandatory conversions and interest deductibility

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2014 Ruling 2014-0523691R3 - Non-Viable Contingent Capital

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Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest non-viable contingent capital sub debt of bank respected as non-participating interest debt 132

20 January 2015 Internal T.I. 2014-0551121I7 F - Interest deductibility

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2 December 2014 CTF Roundtable, Q2(a)

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Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) positive spread/independent servicing source in loss consolidations 165

10 October 2014 APFF Roundtable, 2014-0538261C6 F - Disposition of capital interest/personal trust

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Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2) issuance of note by trust is not distribution of trust property 72
Tax Topics - Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Cost Amount note issuance is not trust property distribution to a beneficiary 201

9 April 2014 Internal T.I. 2014-0519231I7 - Debt forgiveness and guarantees

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Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) - Commercial Debt Obligation guarantee obligation not a commercial debt obligation 149

12 February 2014 Internal T.I. 2012-0443391I7 - cross-border loans and deductibility of interest

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2013 Ruling 2013-0490341R3 - No-type of property spin-off butterfly

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Tax Topics - Income Tax Act - Section 55 - Subsection 55(1) - Distribution s. 55(3.02) public spin-off of CFAs to new sister TC with post butterfly FX loan by TC to DC; new public corp inserted above DC before b/f 399

2013 Ruling 2011-0395091R3 - MFC to MFT Conversion

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12 June 2012 June STEP Roundtable, 2012-0449811C6 - Application of 20(1)(c) if 75(2) applies

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2012 Ruling 2011-0431101R3 - Cross-border spin-off butterfly

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2011 Ruling 2011-0411821R3 - Interest deductibility and loss carry backs

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5 June 2008 TI 2007 - 025221 [partial sale/partial disappearing source]

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2008 IFA Round Table, Q. 10.

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Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(3) 0

15 November 2007 External T.I. 2007-0254941E5 - Interest Deductibility - Second Loan

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2007 Ruling 2007-0245281R3 - windup of income trust on sale of assets:3rd party

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(3.3) capital loss on redemption of trust units following distribution of most of its assets including as capital gains distribution 106
Tax Topics - Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(h) - Subparagraph 53(2)(h)(i.1) no ACB reduction for capital gains distribution by unit trust to bidco 84
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(21) trustees making filings on behalf of terminated fund 46
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(6) realization and distribution of target MFT gain 99
Tax Topics - Income Tax Act - Section 80 - Subsection 80(1) 86
Tax Topics - Income Tax Act - Section 80 - Subsection 80(5) 86

Income Tax Technical News, No. 34, 27 April 2006 under Income Trusts and Interest Deductibility".

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IT-533 "Interest Deductibility and Related Issues" 31 October 2003

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2005 Ruling 2005-0130541R3 - Participating Interest

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3 May 2005 CALU Roundtable Q. 5, 2005-0116661C6 - Interest deductibility on second loan - Gifford

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) contributions of capital 186

2004 Ruling 2004-006195 -

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1999 Ruling 993171 [indirect then direct use]

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1998 APFF Congress, Q. 19

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8 December 1997 T.I. 973056

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1997 Tax Executives Institute Round Table, Q. VIII, No. 9729670

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13 November 1996 T.I. 50963639 (C.T.O. "RESP Interest on Money Borrowed to Contribute")

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) option premium 30

8 October 1996 Memorandum 962852 (C.T.O. "Interest Deductibility")

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1996 Ruling 963802

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1996 Corporate Management Tax Conference Round Table, Q. 7

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1996 Corporate Management Tax Conference Round Table, Q. 1

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Tax Topics - Income Tax Act - Section 20.2 - Subsection 20.2(1) 54

1996 Tax Ruling 960812 (C.T.O. "Loss Consolidation")

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28 July 1995 T.I. 951955 (C.T.O. "IT-315")

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May 1995 Tax Executive Institute Round Table, Q. 16 (C.T.O. "Interest Deductibility - Preferred Shares")

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2 February 1995 Memorandum 943055 (C.T.O. "Interest on Money Borrowed to Pay Interest")

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Income Tax Regulation News, Release No. 3, 30 January, 1995 under "Interest-Bearing Note issued in Consideration for the Redemption or Repurchase of Shares"

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9 September 1994 Memorandum 942195 (C.T.O. "Deductibility of Deep Discounts as Interest and IT-114")

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Revenue Canada Round Table TEI, 16 May 1994, Q. 14 9410430

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1994 A.P.F.F. Round Table, Q. 32

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93 C.R. - Q. 8 (File 932812)

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29 July 1993 Memorandum 9320007

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December 1992 B.C. Tax Executives Institute Round Table, Q. 1, 923039 (C.T.O. "Options"), (October 1993 Access Letter, p.475)

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17 December 1992 Memorandum (Tax Window, No. 27, p. 10, ¶2357)

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October 1992 Central Region Rulings Directorate Tax Seminar, Q. P (May 1993 Access Letter, p. 233)

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1992 Tax Executives Institute Round Table, Q.14 (C.T.O. "Premiums on Debt Obligations")

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92 C.R. - Q.8

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92 C.R. - Q.3

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Tax Topics - Income Tax Act - Section 85 - Subsection 85(1) 74

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1992 A.P.F.F. Annual Conference, Q. 21 (January - February 1993 Access Letter, p. 58)

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92 C.M.TC - Q.1

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14 April 1992 Memorandum (Tax Window, No. 18, p. 12, ¶1845)

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27 March 1992 T.I. (Tax Window, No. 18, p. 12, ¶1838)

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26 March 1992 T.I. (Tax Window, No. 18, p. 2, ¶1831)

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91 C.R. - Q.18

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15 October 1991 T.I. (Tax Window, No. 11, p. 18, ¶1526)

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September 1991 Memorandum (Tax Window, No. 9, p. 19, ¶1467)

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26 July 1991 T.I. (Tax Window, No. 7, p. 2, ¶1376)

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

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25 April 1991 T.I. (Tax Window, No. 2, p. 5, ¶1213)

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24 April 1991 T.I. (Tax Window, No. 2, p. 4, ¶1213)

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11 March 1991 T.I. (Tax Window, No. 1, p. 5, ¶1155)

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1 February 1991 T.I. (Tax Window, Prelim. No. 3, p. 27, ¶1115)

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) 54

16 November 1990 T.I. (Tax Window, Prelim. No. 2, p. 21, ¶1076)

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13 September 1990 Deputy Minister's Office Letter (Tax Window, Prelim. No. 1, p. 19, ¶1007)

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90 C.R. - Q11

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90 C.R. - Q12

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28 June 1990 T.I. (November 1990 Access Letter, ¶1511)

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15 June 1990 T.I. 900645

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15 June 1990 T.I. (November 1990 Access Letter, ¶1510)

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30 April 1990 T.I. 91042-4 [debt not assumed for income-producing property]

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26 February 1990 T.I. 5-9484 [non-deductible where debt assumed in repayment of money previously borrowed]

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8 December 1989 T.I. (May 1990 Access Letter, ¶1210)

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1990 Answers of Scarborough District Office (May 1990 Access Letter, ¶1200, Q. 8)

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8 November 89 Decision Summary (April 90 Access Letter, ¶1170)

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19 September 89 T.I. (February 1990 Access Letter, ¶1100)

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5 September 89 T.I. (February 1990 Access Letter, ¶1101)

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89 C.M.T.C - "Participating Loans"

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89 C.M.TC - Q.1

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88 CPTJ - Q.3

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88 C.R. - "Finance and Leasing" - "Leasing"

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88 C.R. - "Finance and Leasing" - "Interest" - "Purchase of Common Shares"

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88 C.R. - "Finance and Leasing" - "Interest" - "Deep Discount and Zero Coupon Bonds"

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88 C.R. - "Finance and Leasing" - "Interest" - Leveraged Buy-Out"

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88 C.R. - "Finance and Leasing" - "Interest" - "Appraisal Surplus"

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88 C.R. - "Finance and Leasing" - "Interest" - "Decline in Value of Assets"

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88 C.R. - "Finance and Leasing" - "Interest" - "Loans to Non-Arm's Length Persons"

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88 C.R. - "Finance and Leasing" - "Interest" - "Bonus on Early Redemption of Debt"

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88 C.R. - "Finance and Leasing" - "Interest" - "Amounts Paid on Redemption of Bonds or Purchase of Bonds in the Open Market"

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Tax Topics - Income Tax Act - Section 214 - Subsection 214(7) 37

88 C.R. - "Finance and Leasing" - "Interest" - "Participating Loans"

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Hiltz, "Tax Treatment of Interest: Bronfman Trust and the June 2, 1987 Release", 1987 Corporate Management Tax Conference Report, C. 10.

87 C.R. - Q.52

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87 C.R. - Q.54

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85 C.R. - Q.22

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84 C.R. - Q.18

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84 C.R. - Q.59

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84 C.R. - Q. 60

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81 C.R. - Q.39

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80 C.R. - Q.3

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80 C.R. - Q.7

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2) 24

79 C.R. - Q.3

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79 C.R. - Q.6

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ATR-44

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Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) 37

IT-80 "Interest on Money Borrowed to Redeem Shares, or to Pay Dividends".

IT-346R "Commodity Futures and Certain Commodities"

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Articles

Jack Bernstein, Francesco Gucciardo, "Canada-U.S. Hybrid Financing – A Canadian Perspective on the U.S. Debt-Equity Regs", 26 September 2016, p. 1151

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Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper

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Marie-Eve Gosselin, Paul Lynch, "A Review of Interest Deductibility Since Ludco", 2015 CTF Annual Conference paper

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Nathan Boidman, Héléné Gagné, Michael Kandev, "Interest Deductibility in Canada: What's the Fuss?", Tax Notes International, July 13, 2015, p. 16.

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Jack Bernstein, Francesco Gucciardo, "Update on Canada-U.S. Merges and Acquisitions", Tax Notes International, March 16, 2015, p. 993.

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Joseph Frankovic, "Supreme Court to Consider GAAR in Lipson Appeal", CCH Tax Topics, April 10, 2008, No. 1883, p. 1

Charles Taylor, "Hybrid Instruments and Linked Instruments", 2005 Conference Report, c. 16.

Dominic Belley, "Interest Deductible Notwithstanding Form of Contract", Tax for the Owner-Manager, Vol. I, No. 2, April 2001, p. 7

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Tim Edgar, "The Concept of Interest under the Income Tax Act", 1996 Canadian Tax Journal (Vol. 44), p. 277.

Larry F. Chapman, John M. Ulmer, "Canada", Tax Treatment of Hybrid Financial Instruments in Cross-Border Transactions, International Fiscal Association, Vol. LXXXVa, p. 207.

Lewis, "The Taxation of Structured Settlements", British Tax Review, 1994, No. 1, p. 19

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Leslie Morgan, Chris Van Loan, "Recent Developments Involving Tier One Capital Innovative Instruments", Corporate Finance, Vol. VIII, No. 1, 2000, p. 705

K. Penny, "The Toronto-Dominion Bank/Templeton Growth Fund Linked Notes", Corporate Finance, Vol. 6, No. 2, 1998, p. 494.

Edgar, "The Concept of Interest Under the Income Tax Act", 1996 Canadian Tax Journal, Vol. 44, No. 2, p. 277.

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Smith, "Recent Transactions: Debt", 1993 Conference Report, C. 19

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Tremblay, "Foreign Tax Credit Planning", 1993 Corporate Management Tax Conference Report, c. 3, pp. 3:29-3:31

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Richardson, "New Financial Instruments: A Canadian Tax Perspective", 1992 Corporate Management Tax Conference Report, c. 9

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Arnold, "Is Interest A Capital Expense?", 1992 Canadian Tax Journal, No. 3, p. 533.

Flatters, "Assumption of Debt Obligations", 1992 Canadian Tax Journal, Issue No. 2, p. 469.

Dickson, Arnold, "Rubbing Salt into the Wound: The Denial of the Interest Deduction after the Loss of a Source of Income", 1991 Canadian Tax Journal, p. 1473.

Ewens, "Debt-For-Debt Exchanges", 1991 Canadian Tax Journal, p. 1615.

Arnold, Edgar, "Reflections on the Submission of the CBA-CICA Joint Committee on Taxation Concerning the Deductibility of Interest", 1990 Canadian Tax Journal, p. 847.

Brussa, "Strategies for Troubled Times", 1990 Conference Report, c. 9

Crawford, "The Deductibility of Interest", 1990 Conference Report, p. 4:10

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Subparagraph 20(1)(c)(i)

See Also

Alberta v ENMAX Energy Corporation, 2018 ABCA 147

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 247 - New - Subsection 247(2) arm’s length interest rate to sub could not be manipulated by structuring the loan as a junk bond without implicit parental credit support 264
Tax Topics - General Concepts - Tax Avoidance right to structure affairs to reduce taxes (or, here, payments in lieu) inapplicable where consumer assistance purpose defeated 172
Tax Topics - Statutory Interpretation - Hansard, explanatory notes, etc. purpose inferred in part from Legislative Assembly statement of Minister 81
Tax Topics - Income Tax Act - Section 67 test of whether the amount was objectively reasonable 229

Van Steenis v. The Queen, 2018 TCC 78 (Informal Procedure)

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Giguère v. Agence du revenu du Québec, 2018 QCCQ 874

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) interest demanded by a receiver on a fraudulent advance did not qualify as a disposition expense on the property sold to repay the advance 272

Cassan v. The Queen, 2017 TCC 174

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts common law gift was vitiated by loan to donor at unreasonably low rate 746
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(12) although borrowing by taxpayers had a term of 9.3 years, they had a reasonable expectation of refinancing with the promoter’s assistance 466
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) - Paragraph 143.2(7)(a) loans were not bona fide in that not handled with commerciality 655
Tax Topics - Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(d) no requirement to accrue interest on index-linked note in a year when the return thereon was not determinable 577
Tax Topics - Statutory Interpretation - Realization Principle amount should not be recognized until ascertainable 67
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) gratuitous transfer is gift irresepctive of absence of benevolent intent 50

Administrative Policy

3 November 2017 External T.I. 2017-0712141E5 F - Borrowing to make interest-free loans

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2016 Ruling 2015-0602711R3 - Interest on Notes to Non-Residents

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 212 - Subsection 212(3) - Participating debt interest interest ceasing after insolvency event not problematic 92

14 June 2017 External T.I. 2016-0666411E5 - Negative returns on investments

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Loans and Financing Charges negative interest is deductible under s. 9 if there is a reasonable expectation of receiving (positive) interest 130
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) 107

26 May 2016 Internal T.I. 2016-0628741I7 - Interaction of s. 80 and s. 143.4

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(a) no settlement of debt under Plan before conditions precedent fulfilled 158
Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(1) - Right to reduce right to reduce notwithstanding that conditions precedent to interest forgiveness not yet satisfied 311
Tax Topics - Income Tax Act - Section 143.4 - Subsection 143.4(4) s. 143.4(4) caused an immediate income inclusion of prior years’ interest that was to be forgiven at a later date under an approved Plan of Compromise 175

14 March 2016 Internal T.I. 2015-0609671I7 - Earnout, Amalgamation, Cost of Shares and ECE

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) post-amalgamation earnout payment could be applied to increase an s. 88(1)(d) bump of capital property (but not ECP) of the amalgamated target 299
Tax Topics - Income Tax Act - Section 14 - Subsection 14(5) - Eligible Capital Expenditure payments made by Amalco in satisfaction of earnout obligation for acquisition of one precedessor by the other were not ECE 204
Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base earnout payments an addition to cost of shares which had since disappeared 78
Tax Topics - General Concepts - Purpose/Intention attribution of predecessor's intention to Amalco 132

10 October 2014 APFF Roundtable, 2014-0534811C6 F - Interest deductibility

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Subparagraph 20(1)(c)(ii)

Administrative Policy

2016 Ruling 2016-0635051R3 - rollout property to beneficiary non-resident trust

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(2) s. 107(2) rollout of taxable Canadian property by a non-resident former s. 75(2) trust to its corporate beneficiary 365
Tax Topics - Income Tax Act - 101-110 - Section 107 - Subsection 107(4.1) rollout under s. 107(2) available following dissolution of settlor of s. 94(8.2) trust 70

2015 Ruling 2015-0601441R3 - XXXXXXXXXX Partnership - winding up

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 98 - Subsection 98(5) 98(5) wind-up through s. 85 transfer of partnership interest of one partner to the other and preceded by debt assumptions 272
Tax Topics - Income Tax Act - Section 34.2 - Subsection 34.2(11) continuation of s. 34.2(11) reserve following partnership wind-up 324
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) continued availability of s. 20(1)(m) reserve following s. 98(5) wind-up 266
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(n) flow-through of s. 20(1)(n) reserve on s. 98(5) wind-up 262
Tax Topics - Income Tax Act - Section 20 - Subsection 20(24) s. 20(24) election on s. 98(5) wind-up 280
Tax Topics - Income Tax Act - Section 18 - Subsection 18(9) s. 18(9) deduction claimable by transferee former partner following s. 98(5) wind-up 216
Tax Topics - Income Tax Act - Section 147.2 - Subsection 147.2(8) s. 147.2 continuity following s. 98(5) wind-up 336
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(i) no income inclusion on assumption on s. 98(5) wind-up of DSUs and RSUs 329
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements - Paragraph (k) no income on RSU/DSU assumption 20

31 May 2016 Internal T.I. 2016-0638241I7 - interest deductibility

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10 October 2014 APFF Roundtable, 2014-0538141C6 F - Interest deductibility

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