8 October 2004 APFF Roundtable Q. 34, 2004-0087021C6 F - Remboursement de frais de financement -- summary under Paragraph 20(1)(e)

Where a borrower borrows money from an unrelated lender and on-lends to corporations within the group, the reimbursement by those other corporations of the borrower's issue expenses will give rise to deductions to them under s. 20(1)(e)(ii), but the amount of the reimbursement will be included in the income of the borrower pursuant to s. 12(1)(x) unless it deducts the reimbursement under s. 12(2.2).