loan

Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(4)

Where landlords agree to pay tenant inducements over a period of twenty years, the taxpayers would account for the amounts payable as "secured...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
loan
Summary Under
Tax Topics - Income Tax Act - Section 17 - Subsection 17(8) - Paragraph 17(8)(a) - Subparagraph 17(8)(a)(ii)
CFA 1's purchased debt of CFA 2 did not qualify as a loan or advance

Where a taxable Canadian corporation makes a non-interest bearing loan to a controlled foreign affiliate (CFA 1) which, in turn, uses the proceeds...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
loan advance
Summary Under
Tax Topics - Income Tax Act - Section 17 - Subsection 17(1)

With respect to an advance made by a Canadian licensor to a U.S. licensor that was repayable only out of royalties to be earned by the licensor,...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
loan
Summary Under
Tax Topics - Income Tax Act - Section 133 - Subsection 133(8) - Non-Resident-Owned Investment Corporation

Where a promissory note is issued to pay a dividend, the creditor (in this case, an NRO) will not be considered to have made a loan because no...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
loan
Summary Under
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract
interest rate swap not a debt obligation

Interest rate swap transactions between a controlled foreign affiliate of the taxpayer ("BCo") and a foreign financial institution specializing in...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
loan

Merchant v. The Queen, 2009 DTC 282, 2009 TCC 31 -- summary under Subsection 5(1)

Full Title
Merchant v. The Queen, 2009 DTC 282, 2009 TCC 31
Summary Under
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1)
advance is current remuneration if repayable only out of future earnings

In finding that loans made to the taxpayer by his employer were employment income to him when received, Webb, J. stated (at para. 22):

Words and Phrases
loan

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

Full Title
Banner Pharmacaps NRO Ltd. v. The Queen, 2003 DTC 245, 2003 TCC 82, aff'd 2003 FCA 367, 2003 DTC 5642
Summary Under
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Business

The taxpayer was not considered to be engaged in a business of making loans by virtue of the Canadian corporation of which it was a sole...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
loan

Loman Warehousing Ltd. v. Canada, 2000 DTC 6610 (FCA), aff'g 99 DTC 1113, Docket: 98-201-IT-G (TCC) infra -- summary under Subparagraph 20(1)(p)(ii)

Full Title
Loman Warehousing Ltd. v. Canada, 2000 DTC 6610 (FCA), aff'g 99 DTC 1113, Docket: 98-201-IT-G (TCC) infra
Summary Under
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii)
a taxpayer with a warehousing business potentially could have a lending business under a cash pooling arrangement

Noël JA, before rejecting the taxpayer's submission that the post-1993 version of s. 20(1)(p)(ii) contemplated a taxpayer whose ordinary business...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
loan
money-lending business

Langhammer v. The Queen, 2001 DTC 45 (TCC) -- summary under Subsection 18(6)

Full Title
Langhammer v. The Queen, 2001 DTC 45 (TCC)
Summary Under
Tax Topics - Income Tax Act - Section 18 - Subsection 18(6)

Before going on to find that losses sustained by the taxpayer after investing in bonds of a condominium development were deductible under s....

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
loan

Autobus Thomas Inc. v. The Queen, 2000 DTC 6299 (FCA), briefly aff'd 2001 DTC 5665, 2001 SCC 64 -- summary under Subsection 181.2(3)

Full Title
Autobus Thomas Inc. v. The Queen, 2000 DTC 6299 (FCA), briefly aff'd 2001 DTC 5665, 2001 SCC 64
Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3)

The taxpayer partly financed the acquisition of buses by means of its bank purchasing conditional sales contracts from a manufacturer. Marceau...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases
loan

Pages

Subscribe to RSS - loan