Administrative Policy
7 October 2020 APFF Roundtable Q. 16, 2020-0867071C6 F - APFF Q.16 - Withholding tax on swap payment
Before going on to indicate that it no longer imputed interest on mismatched cross-border swap payments, CRA stated:
As set out in various of its...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 16 - Subsection 16(1) | interest is no longer imputed on mismatched cross-border swap payments | 150 |
4 July 2009 Internal T.I. 9415947 - INTEREST RATE SWAP - TERMINATION PAYMENT/RECEIPT
A receipt received by a taxpayer on the termination of a floating-to-fixed interest rate swap was not a capital receipt given that (applying the...
14 September 2004 Internal T.I. 2004-0080911I7 - Swap-termination payments
The CRA position that all amounts payable or receivable pursuant to an interest rate swap agreement (including a termination payment) will be...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Damages | 38 |
2 December 2003 External T.I. 2003-0048555 - VANILLA TYPE INTEREST SWAP
After defining a "plain vanilla" interest rate swap agreement as one where there was no timing mismatch regarding the notional payments going each...
13 July 2001 Internal T.I. 2000-0051017 - STRONG CURRENCY BORROWINGS
Swap payments deducted by the taxpayer under s. 9 were, in large part, incurred to acquire a right under a contract to purchase Japanese yen at...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) | swap payments not interest | 24 |
25 August 2000 External T.I. 2000-0036045 - CROSS CURRENCY SWAPS
The responses contained in Q.60 of the 1984 Revenue Canada Round Table continue to reflect the position of the CCRA.
93 C.R. - Q. 11
All amounts payable or receivable pursuant to an interest rate swap agreement will be considered to be on account of income and will be included...