Regulation 7000

Subsection 7000(1)

Paragraph 7000(1)(a)

Administrative Policy

28 September 1994 External T.I. 9416265 - INTEREST INCOME

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Tax Professionals Mini Round Table - Vancouver - Q. 14 (March 1993 Access Letter, p. 104)

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87 C.R. - Q.49

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84 C.R. - Q.14

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Articles

Holmes, "Supplemental Retirement Arrangements May Provide Deferral for Employee and Deduction for Employer", Taxation of Executive Compensation and Retirement, March 1990, p. 243

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Ulmer, "Taxation of Interest Income", 1990 Conference Report, c. 8.

Paragraph 7000(1)(b)

Administrative Policy

October 1992 Central Region Rulings Directorate Tax Seminar, Q. N (May 1993 Access Letter, p. 233)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) 30

15 April 1992 T.I. (Tax Window, No. 18, p. 21, ¶1864)

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13 June 1991 T.I. (Tax Window, No. 4, p. 14, ¶1306)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) 29

Articles

Duncan Osborne, "CARS and PARS Focus on Stripping Corporate Bonds", Corporate Finance, Vol. XI, No. 1, 2003, p. 1023.

Allgood, "Recent Developments in Asset-Backed Securitization", 1993 Conference Report, c. 16

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Paragraph 7000(1)(c)

Administrative Policy

9 September 2003 External T.I. 2003-0006645 - CALLABLE STEP-UP BOND

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19 May 1992 T.I. 920810 (C.T.O. "Deep Discount Bonds")

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ATR-61, 20 April 1995 "Interest Accruals"

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Articles

Kevin Kelly, "Callable and Extendible Step-Up Notes", Corporate Finance, Vol. XI, No. 4, 2004, p. 1127

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Paragraph 7000(1)(d)

See Also

James McTamney & Co. Ltd. v. MNR, 89 DTC 194 (TCC)

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Administrative Policy

12 December 1996 Internal T.I. 9633886 - T-5 INFORMATION RETURN

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Subsection 7000(2)

Paragraph 7000(2)(a)

See Also

Goulet v. The Queen, 2009 DTC 1875, 2009 TCC 127 (Informal Procedure), aff'd 2011 DTC 5138 [at 6120], 2011 FCA 164

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) discounts not compensation for risk 116

Administrative Policy

28 July 2014 External T.I. 2014-0532651E5 - Loan to charitable foundation

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Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(a) non-interest bearing term loan could trigger PDO rules 162

90 C.R. - Q10

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88 C.R. - "Finance and Leasing" - "Inclusion in Income"

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Paragraph 7000(2)(b)

Administrative Policy

18 March 1993 Memorandum (Tax Window, No. 32, p. 7, ¶2599)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) 28

Articles

Paragraph 7000(2)(c)

Administrative Policy

30 March 2005 External T.I. 2004-0102421E5 F - Placement à rendement progressif

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87 C.R. - Q.55

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Paragraph 7000(2)(c.1)

Administrative Policy

5 April 2004 External T.I. 2004-0068021E5 - Escalator term deposit

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Paragraph 7000(2)(d)

Cases

Ludmer v. Attorney General of Canada, 2018 QCCS 3381, aff'd 2020 QCCA 697

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) recurring fee reduction amounts received for no work were income and taxable under s. 56(2) when directed to controlled company 289
Tax Topics - Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) nature of the legal advice relied upon was unclear 417
Tax Topics - Income Tax Act - Section 152 - Subsection 152(1) improper advancing of “settlement” elements that were not sustainable 45
Tax Topics - Income Tax Act - Section 94.1 - Subsection 94.1(1) equity-linked notes held in BVI company were portfolio investments held with a tax avoidance purpose, but were not subject to 7000(2)(d) interest accrual 576
Tax Topics - General Concepts - Negligence, Fiduciary Duty and Fault damages awarded against CRA for inter alia making unreasonable reassessments 260
Tax Topics - Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit recurring fee reduction amounts received for no work were income from a source 313

See Also

Ludmer v. Attorney General of Canada, 2020 QCCA 697

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Negligence, Fiduciary Duty and Fault abusive and wrongful CRA audit conduct did not engage punitive damages 260

Cassan v. The Queen, 2017 TCC 174

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts common law gift was vitiated by loan to donor at unreasonably low rate 746
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(12) although borrowing by taxpayers had a term of 9.3 years, they had a reasonable expectation of refinancing with the promoter’s assistance 466
Tax Topics - Income Tax Act - Section 143.2 - Subsection 143.2(7) - Paragraph 143.2(7)(a) loans were not bona fide in that not handled with commerciality 655
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) interest on loan to acquire LP units was deductible as there was a prospect of gross income being allocated by LP in 19 years’ time 583
Tax Topics - Statutory Interpretation - Realization Principle amount should not be recognized until ascertainable 67
Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) gratuitous transfer is gift irresepctive of absence of benevolent intent 50

William E. Thomson Associates Inc. v. Carpenter (1989), 69 OR (2d) 545 (C.A.)

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Administrative Policy

2007 Ruling 2007-0237351R3 - Stock-link Notes

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27 June 2001 External T.I. 2001-0079875 - EQUITY-LINKED INVESTMENT CERTIFICATE

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9 August 2001 External T.I. 2001-0076265 - INCOME FROM STOCK-LINKED GIC

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30 November 1996 Ruling 9719753 - CONTINGENT RATE OF RETURN

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28 July 1994 940615 (C.T.O. "T-5 Reporting")

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