5 January 1996 Memorandum 952397 (C.T.O. "Gross-Up Payments")

A gross-up on a debt obligation owing to a Canadian lender will be included in the Canadian lender's income under s. 9 or s. 12(1)(c) even "where...

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A gross-up on a debt obligation owing to a Canadian lender will be included in the Canadian lender's income under s. 9 or s. 12(1)(c) even "where...

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Where a gross-up on interest paid to a non-resident meets the legal definition of interest, it will be deductible by the taxpayer under s....

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Where a gross-up is paid or credited by a Canadian resident to a non-resident pursuant to a loan agreement that is not otherwise exempt from...

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