interest

Summary Under
Tax Topics - Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l)
members providing legitimate debt financing of an NPO can be consistent with the s. 149(1)(l) conditions/ preferred shares that can bear “interest” cannot be issued

A Quebec cooperative received loans from the community in support of it so as to enable it to carry out a project, contribute to its mission and...

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Words and Phrases
interest
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c)
return payable on maturity that was not expressed as a percentage or fraction qualified as interest

A resident individual (the taxpayer) lent a sum to a Barbados borrower pursuant to a debenture contract which provided that the return was payable...

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Words and Phrases
interest
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c)
additional indemnity awarded under CCQ Art. 1619, computed by applying an interest rate to damages award, was interest

The Corporation commenced an action against the Insurer (which had refused to pay insurance proceeds on the death of the life of the Insured...

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Words and Phrases
interest

Agence du revenu du Québec v. Bernardin, 2021 QCCA 625 -- summary under Paragraph 12(1)(c)

Full Title
Agence du revenu du Québec v. Bernardin, 2021 QCCA 625
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c)
interest that arose prior to a class action judgment becoming res judicata was non-taxable – interest arising thereafter was taxable even though judgment not yet quantified

An individual, by virtue of being part of a group of class action claimants, was awarded damages in 2004 of $1,200 for each of the eight winter...

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Words and Phrases
interest
Summary Under
Tax Topics - Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(ii)
grant of in-the-money options to key employee as part of same series could be a significant increase in interest – which otherwise occurs on exercise

Mr. X implemented an estate freeze in favour of his children and a holding corporation respecting his wholly-owned operating corporation, which he...

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Words and Phrases
interest

12 December 2018 Interpretation Letter of the CRA Charities Directorate to Simon Cheung File GC 341217 -- summary under Subsection 188.1(3.2)

The Charities Directorate stated the following respecting a proposal to eliminate a foundation's positive divestment obligation percentage arising...

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Plains Midstream Canada ULC v. Canada, 2019 FCA 57 -- summary under Paragraph 20(1)(c)

Full Title
Plains Midstream Canada ULC v. Canada, 2019 FCA 57
Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)
interest by its nature is symmetrical

As part of a complex set of transactions, a predecessor of the taxpayer agreed to assume a $225M loan that was due in perhaps 43-years’ time and...

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Words and Phrases
interest

Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONCA 727 -- summary under Paragraph (f)

Full Title
Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONCA 727
Summary Under
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f)
additional discount fee, but not admin fee, was interest rather than fee

A typical loan made by the lender (ClearFlow) to the borrower bore base interest rate of 12% p.a. compounded monthly, an administration fee that...

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Words and Phrases
fee
interest

Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONSC 7286, rev'd 2018 ONCA 727 -- summary under Paragraph 20(1)(c)

Full Title
Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONSC 7286, rev'd 2018 ONCA 727
Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c)
a “discount fee” was interest

The typical loan agreement for a loan (a “Loan”) by the respondent (“ClearFlow”) to the applicant (“SPN”) provided for a base interest...

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Words and Phrases
interest

Joint Committee, "Small Business Deduction Rules under Section 125 of the Income Tax Act - Follow-Up to Our Meeting with Canada Revenue Agency", 2 June 2017 Joint Committee Submission to Finance respecting the Small Business Deduction, appending Submission to Randy Hewlett of the Income Tax Rulings Directorate dated 14 February 2017 -- summary under Subparagraph (a)(i)

Joint Committee, "Small Business Deduction Rules under Section 125 of the Income Tax Act - Follow-Up to Our Meeting with Canada Revenue Agency", 2 June 2017 Joint Committee Submission to Finance respecting the Small Business Deduction, appending Submission to Randy Hewlett of the Income Tax Rulings Directorate dated 14 February 2017
Summary Under
Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified Corporate Income - Paragraph (a) - Subparagraph (a)(i)

Issues with cooperatives (p. 2)

Every farming or fishing Canadian-controlled private corporation (“CCPC”) selling substantially all of its...

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Words and Phrases
interest
directly or indirectly

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