2018 Ruling 2017-0732001R3 - XXXXXXXXXX -- attach -- Paragraph 20(1)(c)
interest which the issuer can elect not to pay was treated as non-deductible
Paragraph 20(1)(c)
Plains Midstream Canada ULC v. Canada, 2019 FCA 57 -- attach -- Paragraph 20(1)(c)
interest by its nature is symmetrical
John Tobin, "Infrastructure and P3 Projects", 2017 Conference Report (Canadian Tax Foundation), 10:1-31 -- attach -- Paragraph 20(1)(c)
Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONCA 727 -- attach -- Paragraph 20(1)(c)
daily discount fee had the 3 attributes of interest
Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONSC 7286, rev'd 2018 ONCA 727 -- attach -- Paragraph 20(1)(c)
a “discount fee” was interest
11 September 2015 Internal T.I. 2015-0586301I7 - Premiums received on re-opening of debt -- attach -- Paragraph 20(1)(c)
denied interest expense where a premium was received on extending notes’ maturity
Jack Bernstein, Francesco Gucciardo, "Canada-U.S. Hybrid Financing – A Canadian Perspective on the U.S. Debt-Equity Regs", 26 September 2016, p. 1151 -- attach -- Paragraph 20(1)(c)
1 June 2016 External T.I. 2015-0601211E5 - Mortgage loan from RRSP to make a shareholder loan -- attach -- Paragraph 20(1)(c)
money borrowed by individual from RRSP to make interest-free loan to corporation
Marie-Andrée Beaudry, Dean Kraus, "Selected Income Tax Considerations in the Court-Approved Debt Restructurings and Liquidations", 2015 Annual CTF Conference paper -- attach -- Paragraph 20(1)(c)
R. v. Golini, 2016 TCC 174 -- attach -- Paragraph 20(1)(c)
interest deduction on limited recourse loan
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