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163(a), a taxpayer can deduct such interest only if he or she is liable for the debt.
A taxpayer will be considered to have a tax avoidance motive in respect of a participating interest only if it is reasonable to conclude that one of the main reasons for acquiring, holding or having the interest was tax savings or deferral.
A taxpayer will be considered to have a tax avoidance motive in respect of the acquisition of a participating interest only if it is reasonable to conclude that one of the main reasons for acquiring the interest was Canadian tax savings or deferral.
May claimed that the Service can assess interest only when an underpayment exists.
5) Furthermore, unlike section 263A(f), former section 189 provided for capitalization of interest only with regard to the construction period of "real property.
Thus, if a person is considered a construction owner of a partnership interest only if the family attribution rules were applied more than once, that person is not a constructive owner of the interest.
52) Thus, any pre-1983 payment of assessed interest would be an overpayment of assessed interest only to the extent such payment exceeded the assessed interest owed, including the restricted interest.