Swaps

Table of Contents

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...

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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...

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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...

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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...

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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...

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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...

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