Is an individual who makes an interest-free loan to a non-resident corporation with which the individual does not deal at arm's length required to include in income an amount equaling the interest that would have been received had an arm's length rate been applied in accordance with s. 247? Before responding affirmatively, CRA stated:
Subsection 17(1) generally applies where a non-resident person owes an amount that has been or remains outstanding for more than a year to a related corporation resident in Canada, pursuant to paragraphs 17(1.1)(a) and 17(1.1)(b). …
Except in situations of indirect arrangements or loans referred to in subsection 17(2), section 17 generally does not apply to an amount that is owed to an individual.