Although the CRA doesn’t mention Delle Donne v R, 2015 TCC 150 (discussed here), it recently considered when a victim of a ponzi scheme can write off a bad debt in respect of interest previously included in income. See 2017-0691941I7 (French only). The CRA takes the position that it will generally accept that a claim for a bad debt under paragraph 20(1)(p) of the Income Tax Act (Canada) can be made in the year in which charges are laid with respect to the scheme. The CRA acknowledges, however, that a taxpayer might make the claim in an earlier year, depending on the circumstances.
