Concept
Interest Reduction
Deyab v. Canada, 2020 FCA 222 / 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)
"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 a particular amount to be included in income more than once.\n\nThe inclusion under the Deemed Loan could be reduced under s. 17(1) – B(c) by the amount of interest on Loan 2 included in computing Canco's income under s. 91(1), net of any related expenses."
Related Ideas
- Loan RecordsDeyab v. Canada, 2020 FCA 222 · A. Burden of Proof
- Excess CapacityDeyab v. Canada, 2020 FCA 222 · CRA confirms that CUEC computed in the first (EIFEL) regime year using a 40% ratio must for carryforward purposes be recomputed using the 30% ratio
- CRA ContentDeyab v. Canada, 2020 FCA 222 · Features