Subsection 245(4.1)

Table of Contents

Subsection 245(4.1)
Administrative Policy(3)
Articles(2)

Administrative Policy

2 December 2025 CTF Roundtable, Q.2

In 2013-0477601E5, CRA indicated that, generally, interest would be deductible where an individual used proceeds from the sale of publicly traded...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) no GAAR abuse in using tracing to convert a personal-use to investment-use loan 119

26 November 2023 CTF Conference - "The Future of the GAAR"

Points made by Trevor McGowan on the new GAAR rules included:

  • The introduction of the economic substance rule in s. 245(4.1) was intended to...

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17 May 2023 IFA Finance Update

Object was to introduce an economic substance component without upending GAAR

  • It was part of the elected government’s election platform and...

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Articles

Joint Committee, "GAAR Proposals and Self-Help Transactions", 13 October 2023 Joint Committee Submission

  • The Explanatory Notes examples regarding s. 245(0.1)(a) (RRSP contributions and accelerated CCA claims) do not reflect that many tax planning...

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Joint Committee, "Summary of Comments and Recommendations Provided to the Department of Finance on the General Anti-Avoidance Rule Proposals Released on March 28, 2023", Joint Committee Submission dated 7 June 2023

Need for further examples

  • In addition to the TFSA example provided by Finance, other examples of transactions without a high level of economic...

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