If you borrow money for the purpose of earning investment or business income, the interest you pay on that debt is generally tax deductible.
The loss of source rule as it pertains to a business came up recently in a tax case involving a Montreal accountant who deducted $2,750 and $2,555 of interest expense on his tax returns in 2013 and 2014, respectively. From 2002 to 2007, the taxpayer was self-employed and carried on a business that provided accounting services in the communities of Brossard and Trois‑Rivières. In 2007, he incorporated his business.
After this date, the HELOC was used solely to repay the interest charged by the bank. While the HELOC was also in his spouse’s name, it was done so “for the simple reason that she was the co-owner of the family home.” The taxpayer argued that he should be entitled to continue to deduct the interest expense on the loan even though the business had ceased operating, since the loan subsisted and interest continued to be paid. He argued that under the loss of source rule, “the borrowed money is deemed to be used by the taxpayer for the purpose of earning income from the business, and that this therefore allows for the deduction of interest paid on borrowed money.
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