Bifalgorithm post · Fuscalite · 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)

Interest Reduction

Interest Reduction (Fuscalite · 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…

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Treatment of interest relating to Loan 2 and the Deemed Loan under section 17
CRA's historical position in circumstances such as this
Section 248(28) would not affect the inclusion of interest under section 17 for Loan 2
Section 17 would not require a particular amount to be included in income more than once
The inclusion under the Deemed Loan could be reduced under section 17(1)–B(c)
The reduction equals Loan 2 interest included under section 91(1), net of related expenses

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Interest Reduction

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USR292600b83e2a

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"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."

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