Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 01 JUNE 2005

Cash Collateral Requirements

Blake, Cassels & Graydon LLP
Blake, Cassels & Graydon LLP
Contributor
Blake, Cassels & Graydon LLP

Blake, Cassels & Graydon LLP

As one of Canada’s top business law firms, Blake, Cassels & Graydon LLP (Blakes) provides...

View firm profile
Explore more from Blake, Cassels & Graydon LLP

The Canada Revenue Agency (the CRA) has developed administrative practices concerning the possible impact of cash collateral on the requirement for the 5/25 exemption that the Canadian borrower may not under any circumstances be obligated to repay more than 25% of the principal amount of the obligation within five years from the date on which the principal amount is advanced.

CanadaTax
Author LinkedIn connections

Article by Leslie Morgan, ©2005 Blake, Cassels & Graydon LLP

This article was originally published in Blakes Bulletin on Taxation - April 2005

The Canada Revenue Agency (the CRA) has developed administrative practices concerning the possible impact of cash collateral on the requirement for the 5/25 exemption that the Canadian borrower may not under any circumstances be obligated to repay more than 25% of the principal amount of the obligation within five years from the date on which the principal amount is advanced.

Account Controlled by the Borrower

The borrower may set aside funds in contemplation of the eventual repayment of its obligation. The CRA takes the position that a borrower can be required to make deposits in excess of 25% of the total principal amount within five years to a sinking fund or other account controlled by the borrower without being considered by the CRA to be obligated to pay more than 25% of the principal amount for purposes of the 5/25 exemption. For

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Cryptocurrency Held Through A Bare Trustee: Tax Treatment And The 2026 Reporting Obligations

If you hold cryptocurrency, NFTs or other blockchain assets in someone else’s wallet, or hold assets in your own wallet for someone else, the arrangement is very likely a bare trust. Until recently, that carried almost no compliance consequence. It now carries three reporting obligations to track: the T3 filing for 2026, the T1135, and the proposed Crypto-Asset Reporting Framework from 2027.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

How To Appeal The Toronto Vacant Home (VHT) Tax: Here’s What One Landlord Did To Fight VHT Assessment

Since 2022, the City of Toronto has imposed an annual Vacant Home Tax (VHT) on residential units left unoccupied for more than six months of the year. For most owners the tax is an afterthought: file the annual declaration, confirm the unit was lived in, and move on. But when the City’s administrative process breaks down, an owner can find themselves fighting a five-figure tax bill over a unit they insist was never vacant at all.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

Canadian Prime Minister Announces ‘Productivity Mega Deduction’

Canada's new Productivity Mega Deduction permanently provides immediate expensing for a wide range of depreciable property and Canadian development expenses, dramatically expanding the scope beyond the previously announced Productivity Super Deduction. The measure aims to reduce Canada's marginal effective tax rate on new business investment to 6.4%, positioning it as the lowest among major economies and less than half the U.S. rate.
CanadaTax
Osler, Hoskin & Harcourt LLP
Osler, Hoskin & Harcourt LLP
Article

Productivity Mega Deduction: Key Tax Measures Announced At The Canada Investment Summit

Canada has introduced a permanent Productivity Mega Deduction allowing immediate expensing of up to 100% of eligible capital property costs and Canadian development expenses acquired after September 15, 2026. This measure aims to boost business investment and strengthen Canada's tax competitiveness by expanding immediate expensing eligibility from 15% to approximately two-thirds of capital investments, while reducing the country's marginal effective tax rate to 6.4%.
CanadaTax
McCarthy Tétrault
McCarthy Tétrault
Article

Canada Imposes Counter-Tariffs On C$27.6-Billion Of U.S. Imports, Effective September 8, 2026

Canada has announced C$27.6-billion in counter-tariffs on U.S. imports, effective September 8, 2026, targeting over 700 product classifications across steel, aluminum, dairy, electronics, and other sectors. The measures represent a dollar-for-dollar response to U.S. Section 338 tariffs, with rates ranging from 15% to 50% depending on the product category. The government has also introduced a C$7.5-billion support package for affected Canadian workers and businesses.
CanadaInternational Law
Blake, Cassels & Graydon LLP
Blake, Cassels & Graydon LLP
Article

Manitoba Expanding Land Transfer Tax To Beneficial Transfers

Effective January 1, 2027, Manitoba is expanding its land transfer tax regime to apply to beneficial (unregistered) transfers of land, even where legal (registered) title is not being transferred. The amendments bring Manitoba’s regime more closely in line with Ontario’s and Quebec’s current regimes and will affect transactions involving bare trusts, nominees and other ownership structures that separate legal and beneficial ownership of land.
CanadaTax
Blake, Cassels & Graydon LLP
Blake, Cassels & Graydon LLP
Article

Digging Deeper: Canadian Mining Sector Tax Update

Canada’s mining sector is at an important inflection point. Against a backdrop of growing global demand for critical minerals and increased competition for investment capital, the Canadian federal government has recently introduced a series of tax measures designed to encourage investment and strengthen the competitiveness of Canada’s mining industry. For investors, these measures may meaningfully influence the after-tax economics of projects and financing structures across the mining value chain.
CanadaEnergy and Natural Resources
Blake, Cassels & Graydon LLP
Blake, Cassels & Graydon LLP