Shareholder loan repayment after death

In technical interpretation 2012-0442911C6 (June 2012), the CRA confirmed that

  1. subsection 15(2.6) will apply to prevent the amount of a shareholder loan from being included in the shareholder’s income if his estate repays the loan before the end of the creditor’s year following the year of the advance;
  2. the estate can claim a deduction under paragraph 20(1)(j) if it repays a loan that was included in the shareholder’s income under subsection 15(2); and
  3. neither the estate nor one of its beneficiaries can claim the 20(1)(j) deduction if a beneficiary repays the loan (per technical interpretation 9918015).

Thanks to Enzo Galano for drawing this technical interpretation to my attention.

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