Could CRA confirm that an interest-free loan between two corporations (Aco and Bco) owned by different shareholders does not give rise to a taxable benefit under s. 15(1) or 246(1)?
After discussing s. 15, CRA stated:
[T]o the extent that it were determined that the shareholder of Bco and/or Bco would not have an interest in Aco (and, among other things, that the shareholder of Bco and/or Bco would not be shareholders or contemplated shareholders of Aco), it would appear that the last condition for the application of subsection 246(1) [regarding income inclusion if a direct payment] would not be satisfied. On that basis, subsection 246(1) would be inapplicable in the given situation.