26 October 1989 Ruling 58881 F - Deductibility of Loan Interest

By services, 18 January, 2022
Official title
Deductibility of Loan Interest
Language
French
CRA tags
n/a
Document number
Citation name
58881
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
633650
Extra import data
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"field_release_date_new": "1989-10-26 08:00:00",
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Main text
19(1) File No. 5-8881
  C. Robb
  (613) 957-2744

October 26, 1989

19(1)

We are writing in response to your letter of October 5, 1989.

In our view your request should be addressed to your local District Taxation Office.  However, we do offer the following comments.  As a matter of general principle interest on a loan is deductible if it has been incurred for the purpose of earning income from a business or property.  The decision in Bronfman 87 DTC 5059 (SCC) confirms our position that it is the direct use of the funds which is relevant to determining whether this test is met.

We trust these comments will be of use to you.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate