20 October 1989 Internal T.I. 58737 F - Deductibility of Expenses Incurred to Issue or Sell Warrants

By services, 18 January, 2022
Official title
Deductibility of Expenses Incurred to Issue or Sell Warrants
Language
French
CRA tags
20(1)(e)
Document number
Citation name
58737
Severed letter type
Technical Interpretation - Internal
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
630713
Extra import data
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"field_release_date_new": "1989-10-20 08:00:00",
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Main text
19(1) File No. 5-8737
  S. Leung
  (613) 957-2116

October 20, 1989

Dear Sirs:

Re:  Paragraph 20(1)(e) of the Income Tax Act (the "Act")

We are writing in response to your letter of September 25, 1989 wherein you requested our view on whether expenses incurred by a corporation in the course of an issuance or sale of warrants of the corporation would be deductible pursuant to paragraph 20(1)(e) of the Act.

It is our opinion that such expenses would not be deductible under paragraph 20(1)(e) of the Act as warrants to acquire shares are not one of the qualified properties described in that paragraph.  Warrants would normally be considered as rights to shares rather than shares themselves.

We trust these comments will be of assistance.

Yours truly,

for Director Reorganizations and Non-ResidentsSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch