Subsection 21(1) - Cost of borrowed money
Cases
Saskatchewan Wheat Pool v. R., 99 DTC 5198, [1999] 2 CTC 369 (FCA)
The taxpayers, who were members of a joint venture, did not capitalize interest costs incurred during the construction of a grain elevator under...
Administrative Policy
2013 Ruling 2013-0488351R3 - Conversion of a MFC to a MFT
As a preliminary step to the elimination of a subtrust (OT) of a mutual fund corporation (later converted to a mutual fund trust) using a s....
27 June 2013 External T.I. 2013-0485721E5 - Election to Capitalize Cost of Borrowed Money
Respecting whether a taxpayer could add interest expense to the capital cost of a rental condominium, used less than 10% for personal use, where...
23 February 2004 Internal T.I. 2003-0049157 - ELECTION BORROWED MONEY CAPITALIZE
A s. 21(1) or (3) election may be made by the taxpayer after it has disposed of the relevant depreciable properties.
19 August 1993 External T.I. 9322075 F - Capitalization of Interest
Where money is borrowed to repay accrued interest on debt that was incurred to acquire depreciable property, interest on such further borrowing...
Articles
Shane Onufrechuk, Warren Pashkowick, "Tax Considerations of Major Construction Projects", 2014 Conference Report, Canadian Tax Foundation, 10:1-35.
Capitalization of financing costs (p. 10:22)
[S]ubsection 21(1) allow[s] a taxpayer to capitalize certain costs of financing to any related...
Subsection 21(2) - Borrowed money used for exploration or development
See Also
Mattabi Mines Ltd. v. Min. of Rev., [1982] CTC 382 (SCO), rev'd [1984] CTC 566 (Ont CA), which was, aff'd by [1988] 2 CTC 294, [1988] 2 S.C.R. 175
The taxpayer overlooked making an election in "prescribed form" under a comparable provision of the Corporations Tax Act (Ontario), and the...
Subsection 21(3) - Borrowing for depreciable property
Administrative Policy
19 August 1993 External T.I. 9322075 F - Capitalization of Interest
Where an amount is expended in respect of borrowed money to acquire depreciable property in a year and an amount is also expended in the following...