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").
After indicating that the 2019 Interest constitutes a debt separate from the Loan for s. 15(2) purposes, CRA addressed the question whether a deemed benefit under s. 80.4(2) was to be computed on this $50 debt for Mr. A's 2019 taxation year, and stated:
The underlying purpose of subsection 80.4(2) is to apply to low-interest or non-interest-bearing loans or debt between a corporation and its shareholders. …
While the phrase "incurred a debt" could, if applicable, include accrued interest, it is the CRA's view that accrued interest such as 2019 Interest in the Particular Situation does not meet the meaning of "debt" in the context of a textual, contextual and purposive interpretation of subsection 80.4(2).
… [S]ubsection 80.4(2) would not apply for the 2019 year to the 2019 Interest paid on December 15, 2020, whether or not the Loan is repaid before the Corporation's 2020 year-end.