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 Colubriale v. Canada, 2005 FCA 329 by Un actionnaire vend un immeuble à sa société

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. B(c Reduction

    "The 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."

  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) | Colubriale v. Canada, 2005 FCA 329 | Bifalgorithm | Bifalgorithm