20(1)(f)

Income Tax Folio S3-F6-C1, Interest Deductibility

Income Tax Folio S3-F6-C1, Interest Deductibility Series 3: Property, Investments, and Savings Plans Folio 6: Interest Chapter 1: Interest Deductibility Summary The purpose of this Chapter is to explain the Canada Revenue Agency’s (CRA) position on the deductibility of interest expense under paragraph 20(1)(c). The Chapter also discusses various other provisions of the Act relating to interest deductibility. An amount […]

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TN-44-Exchangeable Debentures

Exchangeable Debentures: Paragraph 20(1)(f) Question 1 At the Canadian Tax Foundation’s 2008 annual conference,[Footnote 18] the CRA was asked to provide its views in respect of the application of paragraph 20(1)(f) to exchangeable debentures in light of the Federal Court of Appeal decision in Tembec Inc. et al. v. The Queen.[Footnote 19] The CRA was not prepared to comment at that

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TN-41-Exchangeable Debentures

Exchangeable Debentures – Paragraph 20(1)(f) In Imperial Oil Ltd. v. Canada, 20 the Supreme Court of Canada held that paragraph 20(1)(f) does not apply to foreign currency losses. The CRA stated verbally at the 2006 Canadian Tax Foundation Annual Conference that commodity-based loans and exchangeable debenture financings currently in place would still be eligible for paragraph 20(1)(f) treatment. The

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