In a triangular amalgamation, is the interest on a third party loan obtained by ParentCo to redeem preferred shares issued by TargetCo as part of the transaction deductible under s. 20(1)(c)? CRA responded that interest on borrowed money used to redeem shares (preferred shares, in this example) would be deductible under s. 20(1)(c), to the extent that the amount of borrowed money does not exceed the capital of the shares, computed prior to the redemption of such shares, and provided that the capital replaced by the borrowing was previously used for eligible purposes.
The interest amount must also be reasonable in the circumstances, and there must be a legal obligation to pay such interest.