Summary Policy

Date
September 3, 2003 (Revised November 23, 2005)

Reference Number
CSP - L06

Key Words
Loan

Policy Statement

The loan of property does not qualify as a gift for income tax purposes. To qualify as a gift, there must be a transfer of property to a qualified donee. It is the Canada Revenue Agency's position that the term transfer involves more than the mere granting of a right to use property for a limited period of time (i.e., a loan of property does not constitute a transfer of property).

References

• Gift (donation), CSP-G01.
• Property, CSP-P05.
• Loan, CIL-1995-011, CIL-1997-008, CIL-1999-019, CIL-2006-001.
• Income Tax Technical News, Issue 17.