CRA confirms deductibility of interest on funds borrowed to finance share repurchase under “fill-the-hole” theory
Paragraph 1.48 of Folio S3-F6-C1 provides that an interest expense on borrowed money used to redeem shares or return capital may be deductible if the borrowed money replaces capital previously used to earn income from a business or property. In 2015-0621401I7, the CRA confirmed that a share repurchase for cancellation may also qualify for “fill-the-hole” treatment as described in paragraph 1.48 of Folio S3-F6-C1.