Words and Phrases - "interest"
18 May 2006 Internal T.I. 2005-0162821I7 F - Imposition - article 1619 du Code civil
additional indemnity awarded under CCQ Art. 1619, computed by applying an interest rate to damages award, was interest
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Words and Phrases
interestAgence du revenu du Québec v. Bernardin, 2021 QCCA 625
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
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Words and Phrases
interest7 October 2011 Roundtable, 2011-0412161C6 F - Timing of the increase in interest - stock option
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
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Words and Phrases
interest12 December 2018 Interpretation Letter of the CRA Charities Directorate to Simon Cheung File GC 341217
debt is an "interest in a corporation, other than shares”
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Words and Phrases
interestPlains Midstream Canada ULC v. Canada, 2019 FCA 57
interest by its nature is symmetrical
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Words and Phrases
interest| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 16 - Subsection 16(1) | s. 16(1) can only apply to a debtor if it equally applies to the creditor | 398 |
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
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | daily discount fee had the 3 attributes of interest | 381 |
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
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified partnership income - Paragraph (c) | 46 |
R. v. Melford Developments Inc., 82 DTC 6281, [1982] CTC 330, [1982] 2 S.C.R. 504
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Words and Phrases
interest| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions | 59 | |
| Tax Topics - Treaties - Income Tax Conventions - Article 11 | guarantee fees were not interest | 82 |
Bennett and White v. The King, 49 DTC 514, [1949] CTC 1, [1949] S.C.R. 287
guarantee payments not interest
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Words and Phrases
interest| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures | guarantee fees paid on construction financing were on capital account | 82 |
| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) | 91 |