10 January 1992 External T.I. 912222A F - Loan to Shareholder - Silden Case (90 DTC 6576)

By services, 7 July, 2022
Official title
Loan to Shareholder - Silden Case (90 DTC 6576)
Language
French
CRA tags
15(2)(a)(ii)
Document number
Citation name
912222A
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
650096
Extra import data
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"field_external_guid": [],
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"field_release_date_new": "1992-01-10 07:00:00",
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Main text

ROUND TABLE - CGA - JANUARY 10, 1992

Officer: Marc Séguin

File: 7-912222

QUESTION #17

Does the Department accept the judgment of the Trial Division of the Federal Court in the Silden case (90 DTC 6576)? According to the judgment, a loan to a shareholder need not have been extended at the time the dwelling is acquired to qualify for the exception in subparagraph 15(2)(a)(ii) of the Act, contrary to the position taken in Interpretation Bulletin IT-119R3.

ANSWER

The Department has filed an appeal from this judgment with the Appeal Division of the Federal Court.