Subsection 21(1) - Cost of borrowed money
Cases
Alberta Wheat Pool v. Canada, 99 DTC 5198, [1999] 2 CTC 369 (FCA)
The taxpayers, who were members of a joint venture, did not capitalize interest costs incurred during the construction of a grain elevator under...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | interest not part of cost if could be deducted | 177 |
Administrative Policy
2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT
As a preliminary step to the elimination of a subtrust (OT) of a mutual fund corporation (later converted to a mutual fund trust) using a s....
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(1) | conversion of MFC to MFT and subtrust elimination | 180 |
| Tax Topics - Income Tax Act - Section 132.2 - Subsection 132.2(1) - Qualifying Exchange | conversion of MFC to MFT and subtrust elimination | 178 |
27 June 2013 External T.I. 2013-0485721E5 - Election to Capitalize Cost of Borrowed Money
Respecting whether a taxpayer could add interest expense to the capital cost of a rental condominium, used less than 10% for personal use, where...
23 February 2004 Internal T.I. 2003-0049157 - ELECTION BORROWED MONEY CAPITALIZE
A s. 21(1) or (3) election may be made by the taxpayer after it has disposed of the relevant depreciable properties.
19 August 1993 External T.I. 9322075 F - Capitalization of Interest
Where money is borrowed to repay accrued interest on debt that was incurred to acquire depreciable property, interest on such further borrowing...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 21 - Subsection 21(3) | 75 |
Articles
Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.
Capitalization of financing costs (p. 10:22)
[S]ubsection 21(1) allow[s] a taxpayer to capitalize certain costs of financing to any related...
Subsection 21(2) - Borrowed money used for exploration or development
See Also
Mattabi Mines Ltd. v. Min. of Rev., [1982] CTC 382 (SCO), rev'd [1984] CTC 566 (Ont CA), which was, aff'd by [1988] 2 CTC 294, [1988] 2 S.C.R. 175
The taxpayer overlooked making an election in "prescribed form" under a comparable provision of the Corporations Tax Act (Ontario), and the...
Subsection 21(3) - Borrowing for depreciable property
Administrative Policy
19 August 1993 External T.I. 9322075 F - Capitalization of Interest
Where an amount is expended in respect of borrowed money to acquire depreciable property in a year and an amount is also expended in the following...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 21 - Subsection 21(1) | 139 |