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Interest Deductibility in Canada: What’s the Fuss?

Authors: Nathan Boidman, Michael N. Kandev and Héléna Gagné

This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business-related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada Revenue Agency’s administrative views on the matter and the judgment by the Tax Court of Canada in a Canada-U.S. cross-border matter and, separately, the OECD’s base erosion and profit-shifting initiative.

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