Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(2)		77
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		96
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Expenses - A - Paragraph (d)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(3)		113
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		73
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		66
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4) - Paragraph 18.2(4)(c)		104

Group Ratio

Articles

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022

Grind removed (p. 9)

The amended “group ratio” definition has removed the progressive grind (formerly in para. (b) of “group ratio”).

Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		117
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		37
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		97
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings - Paragraph (b)		37
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		63
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		100
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2) - Paragraph 18.21(2)(a)		53

Relevant Period

Articles

Joint Committee, "Summaries of Feedback on the EIFEL Administration", 2 November 2024 Joint Committee Submission to the CRA International and Large Business Directorate

Application of group ratio where entry or exit from group (p. 3)

Given that the group ratio is calculated for a consolidated group for a...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Ultimate Parent		92
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Cumulative Unused Excess Capacity		51
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		373

Ultimate Parent

Articles

Joint Committee, "Summaries of Feedback on the EIFEL Administration", 2 November 2024 Joint Committee Submission to the CRA International and Large Business Directorate

Family trusts as ultimate parents (p. 3)

Although there are many instances in which a family trust could be treated as the ultimate parent of a...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Relevant Period		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Cumulative Unused Excess Capacity		51
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		373

Subsection 18.21(2)

Articles

Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper

No ability to accrue unused excess capacity (p. 17)

S. 18.21(2) reflects an intention that a taxpayer subject to the group ratio cannot accrue...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		161
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		126
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		106
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		222
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(E)		164
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Exempt Interest And Financing Expenses		89

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

Zero tolerance for errors (p. 39)

Under s. 18.21(2), if an election is made that allocates an amount greater than the specified limits, the...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(i)		79
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(ii)		138
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity - Paragraph (c) - Subparagraph (c)(iii) - Clause (c)(iii)(A)		94
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(9)		143
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues - Paragraph (g)		101
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excess Capacity		137
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		42

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

Effective transfer of excess capacity to or from group trusts (p.10)

Unlike the s. 18.2 rules, under which there is no ability for trusts within a...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(12)		156
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		104
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (a)		140
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (b)		121
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a.1)		173
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(3)		194

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Potential difficulties in annually assessing whether the election should be made or is practicable

Application of the group ratio regime requires...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Entity		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(2)		77
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - A		96
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Expenses - A - Paragraph (d)		39
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(3)		113
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		73
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Acceptable Accounting Standards		85
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4) - Paragraph 18.2(4)(c)		104

Paragraph 18.21(2)(a)

Articles

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022

Can be different reporting currencies (p. 9)

Under an amendment to s. 18.21(2)(a) of the group ratio rules, the requirement that the tax...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Relevant Affiliate Interest And Financing Expenses		117
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(A)		37
Tax Topics - Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(f.11) - Subparagraph 95(2)(f.11)(ii) - Clause 95(2)(f.11)(ii)(D)		97
Tax Topics - Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Earnings - Paragraph (b)		37
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues		63
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (h)		55
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(4)		100
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(1) - Group Ratio		28

Subsection 18.21(3)

Articles

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

No requirement to determine “excess capacity” (p. 9)

Unlike [under s. 18.2], there is no requirement to determine the “excess capacity”...

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Locations of other summaries		Wordcount
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(12)		156
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Excluded Interest		104
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - B - Paragraph (a)		140
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Adjusted Taxable Income - C - Paragraph (b)		121
Tax Topics - Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a.1)		173
Tax Topics - Income Tax Act - Section 18.21 - Subsection 18.21(2)		79

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Section 18.21

Table of Contents

Subsection 18.21(1)

Acceptable Accounting Standards

Articles

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Group Ratio

Articles

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022

Relevant Period

Articles

Joint Committee, "Summaries of Feedback on the EIFEL Administration", 2 November 2024 Joint Committee Submission to the CRA International and Large Business Directorate

Ultimate Parent

Articles

Joint Committee, "Summaries of Feedback on the EIFEL Administration", 2 November 2024 Joint Committee Submission to the CRA International and Large Business Directorate

Subsection 18.21(2)

Articles

Larry Nevsky, Brian Kearl, Aaron Chai, "Unexpected EIFEL Issues and Uncertainties", Draft 2024 CTF Annual Conference paper

Saira Bhojani, Eivan Sulaiman, "EIFEL Rules", Draft 2022 CTF Annual Conference paper

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

PWC, "Tax Insights: Excessive interest and financing expenses limitation (EIFEL) regime", Issue 2022-06, 15 February 2022

Paragraph 18.21(2)(a)

Articles

EY, "Revised EIFEL proposals", Tax Alert 2022 No. 43, 10 November 2022

Subsection 18.21(3)

Articles

EY, "Proposed EIFEL rules", Tax Alert 2022 No. 13, 9 March 2022

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