Chapter

CRA comments on a s. 17(1) inclusion under a s. 17(2) B2B loan and the partially offsetting FAPI deduction under s. 17(1) – B(c)

From Deyab v. Canada, 2020 FCA 222 by Sambif

Concepts

  1. Deemed Loan

    "Canco wholly owns a Barbados subsidiary (“Barbco”), which has a non-interest-bearing loan (\"Loan 1\") owing to Canco. In addition to earning interest on term deposits, Barbco also holds a loan (\"Lo

  2. Interest Reduction

    "CRA further noted its historical position that, in circumstances such as this, s. 248(28) would not affect the inclusion of interest under s. 17 in respect of Loan 2, because s. 17 would not require

  3. Subsequent Year

    "CRA also addressed the reference in B(c) to a reduction for amounts included in computing Canco’s income under s. 91(1) not only in the particular year but also in a subsequent year of Canco, provide

CRA comments on a s. 17(1) inclusion under a s. 17(2) B2B loan and the partially offsetting FAPI deduction under s. 17(1) – B(c) | Deyab v. Canada, 2020 FCA 222 | Bifalgorithm | Bifalgorithm