Subsection 33.1(1)
Eligible Loans
Administrative Policy
1 December 1992 T.I. (Tax Window, No. 27, p. 15, ¶2347)
It is a question of fact whether existing loans booked in Canada or offshore that are renegotiated, refinanced or rolled over constitute new loans...
26 June 1992 T.I. 920271 (December 1992 Access Letter, p. 12, ¶C20-1136)
Re the eligibility of loans made by an IBC to a non-resident buyer for the purpose of financing the importation of Canadian goods and services to...
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 33.1 - Subsection 33.1(1) - Non-Resident Person | 14 |
26 April 1991 Memorandum (Tax Window, No. 2, p. 29, ¶1218)
Where a loan is acquired from a foreign bank, the reasonable enquiries as to the use of the loan proceeds should be made in respect of the time...
Non-Resident Person
Administrative Policy
26 June 1992 T.I. 920271 (December 1992 Access Letter, p. 12, ¶C20-1136)
Shipping companies to which s. 250(6) applies are non-residents for purposes of s. 33.1.
Locations of other summaries | Wordcount | |
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Tax Topics - Income Tax Act - Section 33.1 - Subsection 33.1(1) - Eligible Loans | 52 |
Subsection 33.1(4)
Administrative Policy
30 September 1992 T.I. (Tax Window, No. 24, p. 11, ¶2230)
Discussion of various issues arising under s. 33.1.