Words and Phrases - "return"

a
94
b
44
c
88
d
59
e
44
f
33
g
20
h
15
i
77
j
2
k
3
l
32
m
63
n
29
o
43
p
84
q
3
r
81
s
98
t
48
u
18
v
11
w
25
y
2

Supplemental instructions and guidance for filing under the excessive interest and financing expenses limitation rules, CRA Webpage, 3 June 2026

Summary Under
Tax Topics - Income Tax Act - Section 18.2 - Subsection 18.2(1) - Interest and Financing Revenues - B - Paragraph (a)

Netting of amounts under A(d) and B(a) of IFR is intended to reflect the real economic return included in income

IFR – Application of Return on Funding Requirements

In computing IFR, the Return on Funding Requirements are applied from the perspective of the taxpayer expecting the return in respect of a loan or other financing. …

The netting of amounts under paragraph (d) of variable A and paragraph (a) of variable B of the definition of IFR is intended to reflect the real economic return included in income in a particular tax year in respect of all loans or other financings, where each such loan or other financing is specifically linked to the provision of funding by the taxpayer (or a non arm’s length person or partnership) to another person as part of its business or an investment activity intended to earn income.

“Return” in A(d) and B(a) of IFR references financing yield

Meaning of “return”

… The word “return” draws its meaning from the requirement that there be a recompense, reward or compensation in respect of a loan or other financing owing to, or provided by, the taxpayer or a non arm’s length party. It is commonly understood to mean the yield or profit generated from such a loan or other financing.

Words and Phrases
return