23 December 2009 External T.I. 2009-0341951E5 F - Déductibilité des frais d'emprunt -- summary under Subparagraph 20(1)(e)(ii)

In the context of a mortgage loan used to acquire investments that generate different types of property income, are expenses incurred as a result of the requirements of a financial institution that are incidental to an application for a loan, deductible pursuant to paragraph 20(1)(e)? CRA responded:

[A]ll costs that are incidental to an application for a loan and that are incurred as a result of the lender's requirements may be deductible by virtue of subparagraph 20(1)(e)(ii) if the other conditions of paragraph 20(1)(e) are satisfied. In our view, notary fees incurred to provide the lender with security that satisfies the lender's requirements are deductible by virtue of paragraph 20(1)(e).

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