Words and Phrases - "loan"

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13 June 2012 External T.I. 2011-0416781E5 F - Entente contractuelle particulière

intragroup charges to reflect use of each other’s capital under cash pooling arrangement are non-deductible

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Words and Phrases
loan

5 July 2012 Internal T.I. 2010-0388551I7 F - Fiducie - retour de sommes

capital gain distributed by family trust to children and purportedly lent by them to their parents (also beneficiaries) was instead included in the parents’ income under s. 104(13)

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) s. 75(2) does not apply to an estate freeze as the corp does not own its treasury shares issued to the trust 154
Tax Topics - Income Tax Act - 101-110 - Section 105 - Subsection 105(1) income distributed to daughter-in-law who in fact was not a beneficiary includible in her income under s. 105(1) but not deductible by trust under s. 104(6) 156
Tax Topics - Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(6) Foisy test of mental element accepted 221

Meilleur v. The Queen, 2016 TCC 287

retired individuals making 5 high-yield loans on a pooled basis lacked a money-lending business

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Words and Phrases
loan

26 April 2016 Internal T.I. 2015-0623571I7 - one-time salary transition payment

employee advance not a “loan”

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) advance to employee is current s. 5 income 229
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) deduction for repayment of transitional advance 155

13 June 2012 Internal T.I. 2012-0448961I7 F - Paiements en trop faits par un employeur

grant of extended period for employee to repay overpayment was not a s. 80.4 loan

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) salary mistakenly paid after expiry of sick leave period and then repaid, treated as clerical error rather than s. 8(1)(n) adjustment 276

17 November 1999 T.I. 990126

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 97 - Subsection 97(2) 108

21 March 2001 Internal T.I. 2000-005629 -

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Words and Phrases
loan

13 January 2012 Internal T.I. 2011-0414111I7 F - Deemed Interest Incomes - Exception 17(8)

CFA 1's purchased debt of CFA 2 did not qualify as a loan or advance

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Words and Phrases
loan advance

12 March 1992 External T.I. 5-910839 -

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Words and Phrases
loan

5 November 1999 Memorandum 991063

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Words and Phrases
loan

29 August 2011 Internal T.I. 2009-0336671I7 - Derivative

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Timing 185

Merchant v. The Queen, 2009 DTC 282, 2009 TCC 31

advance is current remuneration if repayable only out of future earnings

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 131

Banner Pharmacaps NRO Ltd. v. The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Timing 87

Loman Warehousing Ltd. v. Canada, 2000 DTC 6610 (FCA), aff'g 99 DTC 1113, Docket: 98-201-IT-G (TCC) infra

a taxpayer with a warehousing business potentially could have a lending business under a cash pooling arrangement

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Words and Phrases
loan money-lending business

Langhammer v. The Queen, 2001 DTC 45 (TCC)

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) occasional loans were money-lending business given that done similarly to a money lender 245

Autobus Thomas Inc. v. The Queen, 2000 DTC 6299 (FCA), briefly aff'd 2001 DTC 5665, 2001 SCC 64

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Words and Phrases
loan

In re Touquoy Gold Mining Co. (1906), 1 E.L.R. 142 (Nova Scotia)

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Words and Phrases
loan borrowing

Alberta and Southern Gas Co. Ltd. v. The Queen, 76 DTC 6362, [1976] CTC 639 (FCTD), aff'd 77 DTC 5244 [1977] CTC 388 (FCA), aff'd 78 DTC 6566, [1978] CTC 780, [1979] 1 S.C.R. 36

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Words and Phrases
loan

Canada Deposit Insurance Corp. v. Canadian Commercial Bank, [1992] 3 S.C.R. 558

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Words and Phrases
loan

Cooper v. The Queen, 88 DTC 6525, [1989] 1 CTC 66 (FCTD)

interest-free loan recognized as obligation rather than benefit

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Words and Phrases
loan
Locations of other summaries Wordcount
Tax Topics - General Concepts - Illegality income tax consequences attaching to illegal loan 75
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) interest-free loan 102