Words and Phrases - "interest"
7 January 2025 External T.I. 2022-0945291E5 F - Intérêts versés sur des obligations communautaires d’une coopérative
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...
13 August 2004 Internal T.I. 2004-0076861I7 F - Investissement à l'étranger
A resident individual (the taxpayer) lent a sum to a Barbados borrower pursuant to a debenture contract which provided that the return was payable...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) | s. 75(2) would apply where loan proceeds would ultimately revert to the taxpayer | 74 |
| Tax Topics - Income Tax Act - Section 108 - Subsection 108(2) - Paragraph 108(2)(a) | suspension of redemption right for more than one year would disqualify as s. 108(2)(a) trust | 131 |
18 May 2006 Internal T.I. 2005-0162821I7 F - Imposition - article 1619 du Code civil
The Corporation commenced an action against the Insurer (which had refused to pay insurance proceeds on the death of the life of the Insured...
Agence du revenu du Québec v. Bernardin, 2021 QCCA 625
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...
7 October 2011 Roundtable, 2011-0412161C6 F - Timing of the increase in interest - stock option
Mr. X implemented an estate freeze in favour of his children and a holding corporation respecting his wholly-owned operating corporation, which he...
12 December 2018 Interpretation Letter of the CRA Charities Directorate to Simon Cheung File GC 341217
The Charities Directorate stated the following respecting a proposal to eliminate a foundation's positive divestment obligation percentage arising...
Plains Midstream Canada ULC v. Canada, 2019 FCA 57
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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|---|---|---|
| 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
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...
| 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 |
Solar Power Network Inc. v. ClearFlow Energy Finance Corp., 2018 ONSC 7286, rev'd 2018 ONCA 727
The typical loan agreement for a loan (a “Loan”) by the respondent (“ClearFlow”) to the applicant (“SPN”) provided for a base 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
Issues with cooperatives (p. 2)
Every farming or fishing Canadian-controlled private corporation (“CCPC”) selling substantially all of its...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 125 - Subsection 125(7) - Specified partnership income - Paragraph (c) | 62 |
R. v. Melford Developments Inc., 82 DTC 6281, [1982] CTC 330, [1982] 2 S.C.R. 504
In the absence of this provision, "interest" in Part XIII would refer primarily to "the payment of rent by a borrower for the use of the principal...
| 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 Construction Co. v. Minister of National Revenue, 49 DTC 514, [1949] CTC 1, [1949] S.C.R. 287, [1949-1950] DTC 514
In finding that annual amounts described in various resolutions of the taxpayer as "interest" in fact were guarantee payments, Locke J. stated (p....
| 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 |
Reference as to the Validity of Section 6 of the Farm Security Act, 1944 of Saskatchewan, [1947] S.C.R. 394, aff'd [1949] AC 110
Section 6 of the Farm Security Act 1944 (Saskatchewan) provided that in the event of a crop failure, the principal of a mortgage on a farm would...
Morscher v. MNR, 92 DTC 2214, [1992] 2 CTC 2534 (TCC)
The taxpayer, who carried on a commercial litigation practice in partnership with another lawyer, was denied the deduction of interest which...
Pike v. Revenue and Customs Commissioners, [2014] BTC 33, [2014] EWCA Civ 824
The taxpayer subscribed for loan stock of a family company at a price equal to its principal amount. Although the loan stock did not bear any...