Would s. 12(1)(x) apply in a situation where a corporation (the "Borrower") incurred financing expenses in connection with money that was borrowed from unrelated lenders and then lent to related corporations that reimbursed the Borrower for the financing expenses that it incurred? CRA stated:
It is our view that the amounts received by the Borrower as reimbursement of the financing costs incurred in the course of a borrowing for the purpose of earning income from a business or property could, depending on the case, be included in income pursuant to paragraph 12(1)(x) ITA.