Supercom Canada Limited v. The Queen, 2005 DTC 1438, 2005 TCC 589 -- summary under Subparagraph 20(1)(p)(i)

By services, 28 November, 2015

The taxpayer, which sold substantial quantities of its products to a U.K. corporation with which it was not dealing at arm's length on favourable credit terms, was able to take a deduction for the substantial receivables owing to it by the U.K. company when the U.K. company's business failed and it was wound up. Hershfield J. found that it was contrary to normal interpretative principles to recharacterize the trade receivables owing to the taxpayer by the U.K. company as advances of capital and noted (at p. 1445) that various "cases established that a trade receivable remains such until specific actions are taken to change its nature".

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trade receivables not converted to loans
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