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Exception to Ejusdem Generis 2. of Consider the exception to ejusdem generis canon construction and apply it to former subsection 224 (1.3) of the
Exception to Ejusdem Generis 2. of Consider the exception to ejusdem generis canon construction and apply it to former subsection 224 (1.3) of the Income Tax Act ("ITA"), which defined the term "security interest". Former subsection 224 (1.3) of the ITA stated: "224 (1.3) 'security interest' of a taxpayer is a right to repayment of a bond, debenture, mortgage, promissory note, or any other similar indebtedness whatever" BuzzCo is the parent corporation of its wholly-owned subsidiary corporation, OpCo. BuzzCo made a loan to OpCo in the amount of $200,000, which is reflected only by the appropriate journal entries in each of BuzzCo's and OpCo's Simply Accounting computer software. For the purposes of this former statutory provision, would this loan receivable by BuzzCo from OpCo represent a "security interest" of BuzzCo? Yes or No (1 mark) Explain why or why not (3 marks)
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