In 2014-0532651E5, the CRA said that a non-interest-bearing loan from one Canadian corporation to another (the latter, a charitable foundation) may engage s. 69(1)(a) if the loan were not repayable on demand.  In these circumstances, the CRA is of the view that the cost of the loan may be less than the principal amount – engaging other rules such as the interest accrual rules in s. 12(9) and Regulation 7000.  However, I find it difficult to see how s. 69(1)(a) could apply in these circumstances.  Even if the two corporations are not dealing at arm’s length, it would seem difficult to conclude that the corporation which makes the loan actually acquires the loan “from” the other corporation (as required by the text of s. 69(1)(a)).