Section 80.4

Subsection 80.4(1) - Loans

Cases

Attorney General of Canada v. Hoefele, 95 DTC 5602 (FCA)

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Tax Avoidance form matters 76
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) interest rate subsidy did not increase net worth 98

See Also

Wolf v. MNR, 92 DTC 1858 (TCC)

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Fingold v. MNR, 92 DTC 2011 (TCC)

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Administrative Policy

26 April 2016 Internal T.I. 2015-0623571I7 - one-time salary transition payment

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) advance to employee is current s. 5 income 229
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) deduction for repayment of transitional advance 155

6 September 2013 External T.I. 2012-0463501E5 - Reduced Interest Rate Credit Cards

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13 June 2012 Internal T.I. 2012-0448961I7 F - Paiements en trop faits par un employeur

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) salary mistakenly paid after expiry of sick leave period and then repaid, treated as clerical error rather than s. 8(1)(n) adjustment 276

2 March 2012 Internal T.I. 2011-0422811I7 - Loan received in capacity as an employee

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13 January 1993 T.I. 922191 (November 1993 Access Letter, p. 500, ¶C76-077)

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13 January 1992 T.I. (Tax Window, No. 15, p. 20, ¶1695)

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4 November 1991 Memorandum (Tax Window, No. 13, p. 11, ¶1585)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(15) 47

28 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 21, ¶1110)

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IT-421R "Benefits to Individuals, Corporations and Shareholders from Loans or Debt"

Articles

Frankovic, "Interest Subsidies and Interest-Free Home Relocation Loans - No Taxable Benefits", Tax Topics, No. 1336, 16 October 1997, p. 1.

Dunbar, "Revenue Canada Establishes Policy on Loan-Related Benefits", Taxation of Executive Compensation and Retirement, June 1991, p. 451.

"Guidelines Are Established to Determine if a Loan is Made by Virtue of Employment", Taxation of Executive Compensation and Retirement, March 1990, p. 249.

"Low Interest Foreign Currency Loans May Trigger Taxable Benefit if a Downside Protection is Afforded by Employer", Taxation of Executive Compensation and Retirement, March 1990, p. 250.

Dewling, "Bridging Loan to Custodian Under Retirement Compensation Arrangement Is Not Subject to Interest Benefit Provisions", Taxation of Executive Compensation and Retirement, December 1989/January 1990

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Subsection 80.4(1.1) - Interpretation

Administrative Policy

24 February 2000 External T.I. 1999-000480 -

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Subsection 80.4(2) - Idem [Interpretation]

Cases

Vine Estate v. The Queen, 89 DTC 5528 (FCTD)

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Administrative Policy

16 August 2017 Internal T.I. 2015-0622751I7 - Part XIII Tax on Benefit to Non-resident

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(9) s. 15(9) applies to interest-free loan between two foreign affiliates 257
Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) use of s. 160 to collect s. 15(9) liability of indirect FA on dividends paid to Canco 269
Tax Topics - Income Tax Act - Section 215 - Subsection 215(1) CFA liable for failure to "withhold" and remit Pt XIII tax on interest-free benefit on loan to NR sister of its Cdn grandparent 122
Tax Topics - Income Tax Act - Section 227.1 - Subsection 227.1(1) s. 227.1 liability can extend to NR directors of a CFA 168
Tax Topics - Income Tax Act - Section 214 - Subsection 214(3) - Paragraph 214(3)(a) benefit from interest free loan by CFA to Canco sister deemed to be a dividend subject to Pt XIII tax 160

15 February 1994 T.I. 933046 (C.T.O. "Mortgage Interest Subsidies")

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5 February 1993 T.I. (Tax Window, No. 28, p. 12, ¶2407)

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October 1992 Central Region Rulings Directorate Tax Seminar, Q. H (May 1993 Access Letter, p. 230)

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84 C.R. - Q.84

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Subsection 80.4(3) - Where ss. (1) and (2) do not apply

Cases

Marchand v. Canada, 97 DTC 5272 (FCA)

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Administrative Policy

19 December 2001 Internal T.I. 2001-010941 -

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Paragraph 80.4(3)(b)

See Also

Quigley v. The Queen, 96 DTC 1057 (TCC)

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Words and Phrases
included

Administrative Policy

6 April 2018 External T.I. 2018-0738871E5 F - Shareholder

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) s. 15(2) held in suspense until time period passes/s. 80.4(2) inclusion until s. 15(2) inclusion reverses such inclusion 171

Subsection 80.4(4) - Interest on loans for home purchase or relocation

Administrative Policy

4 April 1995 T.I. 943243 (C.T.O. "Low Interest Loans")

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