On January 1, 2019, the Corporation (which had a calendar year) made the loan of $1,000, bearing interest at 5% per annum, to a shareholder (Mr. A). On December 31, 2020, Mr. A had not repaid the Loan or paid any interest. The interest on the Loan that was due on January 1, 2020 for the 2019 taxation year was $50 (the "2019 Interest").
Does the required inclusion of the $1,000 Loan amount in Mr. A's income for 2019 mean that no unpaid interest is required to be included in that same calculation pursuant to s. 15(2), and is the 2019 Interest a separate debt from the Loan for s. 15(2) purposes?
After describing its similar position in 2014-0526731C6 regarding s. 90(6), CRA stated:
[T]he 2019 Interest would be a separate debt from the Loan for the purposes of subsection 15(2). If the 2019 Interest was unpaid on December 31, 2020, the exception in subsection 15(2.6) would not apply … . Mr. A would then be required to include the amount of the 2019 Interest in his income for 2019 … regardless of whether the Loan was also included in Mr. A's income under subsection 15(2).