21 November 1989 External T.I. 58680 F - Deduction of Interest on Funds Borrowed to be Loaned to Subsidiary at No Interest - IT-445

By services, 18 January, 2022
Official title
Deduction of Interest on Funds Borrowed to be Loaned to Subsidiary at No Interest - IT-445
Language
French
CRA tags
n/a
Document number
Citation name
58680
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
630927
Extra import data
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"field_release_date_new": "1989-11-21 07:00:00",
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Main text
19(1) File No. 5-8680
  Peter Lee
  (613) 957-2745

November 21, 1989

Dear Sirs:

Re:  Interpretation Bulletin IT-445

We are writing in reply to your letter of September 13, 1989, wherein you requested our opinion with respect to our administrative position in paragraph 7 of IT-445.

The Department will generally permit a deduction for the full interest expense incurred when a taxpayer borrows money at interest to be loaned to its Canadian subsidiary, at no interest,if all the conditions set out in paragraph 7 of IT-445 are met during the outstanding period of the loan.

Our view is not an advance income tax ruling and accordingly is not binding on the Department.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate