The client
A self-employed retailer in Wasaga Beach, sole proprietor of an independent shop, wanting to refinance her home to fund an inventory expansion and a modest renovation to the storefront. Her accountant had flagged that structuring the refinance correctly could make the interest tax-deductible; a generalist mortgage rep had told her the opposite before she came to a broker.
Business
Sole proprietor, independent retail shop
Two-year average net income $57,500/yr, $4,792/mo
His employment
Salaried spouse, $46,000/yr
$3,833/mo
Property
$480,000 appraised, Wasaga Beach
Existing mortgage balance $210,000
The ask
$360,000 refinance
$150,000 released into the business
The problem
The advice she'd been given was confident and wrong: the interest can't be deductible because the loan is registered against your house, not your business. On that understanding she'd nearly gone looking for a far more expensive unsecured business line of credit instead of refinancing a mortgage she already qualified for.
Security has nothing to do with it. The Canada Revenue Agency's own position, set out in Income Tax Folio S3-F6-C1, is built entirely around a different question.
What actually governs deductibility under paragraph 20(1)(c)
- ▸Interest is deductible where borrowed money is used for the purpose of earning income — the test looks at the current use of the funds, not what the lender registered as security for the loan
- ▸A mortgage secured against a principal residence, with the proceeds actually deployed into a genuine income-earning business, meets that test the same as an unsecured business loan would
- ▸What defeats a deduction is not the security — it is a failure to trace the borrowed money to that use, especially once it is commingled with money from other sources
The real obstacle was never approval. It was making sure that, years from now, every dollar of the $150,000 could still be traced to the business rather than absorbed into her household's general cash flow — which required a specific structure at closing, not just a stated intention.
The numbers
This is a conventional refinance to 75% loan-to-value, so the ratios were sized against the lender's own policy rather than an insurer's ceiling — one of the practical differences covered in insured vs. uninsured underwriting — and cleared comfortably.
| The refinance | Amount |
|---|---|
| Appraised value | $480,000 |
| Existing mortgage balance | $210,000 |
| Released to the business | +$150,000 |
| New mortgage | $360,000 |
| Sizing and rate | Figure |
|---|---|
| Loan-to-value ($360,000 ÷ $480,000) | 75.0% |
| Contract rate, 5-year fixed (illustrative, not a quote) | 5.49% |
| Minimum qualifying rate | 7.49% |
| Monthly payment at the qualifying rate | $2,631 |
| Ratios on $8,625/month combined income | Figure |
|---|---|
| Housing costs (qualifying payment + $310 tax + $150 heat) | $3,091 |
| GDS | 35.8% |
| TDS (housing + $340 vehicle loan) | 39.8% |
Both ratios cleared with room; the deductibility question sat entirely on the other side of closing, in how the $150,000 was actually disbursed and spent from there.
The solution
A mortgage agent licensed under Ontario's Mortgage Brokerages, Lenders and Administrators Act treated the refinance and the tax structuring as two connected but separate jobs.
First, corrected the security misconception directly, walking through Folio S3-F6-C1's own framing: what secures a loan is irrelevant to paragraph 20(1)(c); what the borrowed money is used for is everything.
Second, had the payout instructions route the full $150,000 as a single lump sum into a newly opened business account used for nothing else — not blended into a readvanceable line of credit, not netted against the existing mortgage, and not deposited into her existing business operating account where it would mix with regular sales revenue.
Third, coordinated with her accountant on what CRA calls ‘cash damming’ — segregating the borrowed funds so every dollar leaving that account for inventory or the renovation stays traceable to the loan, while ordinary business revenue continues through her existing account untouched. The same discipline is worth applying wherever a self-employed income worksheet mixes business and personal cash flow.
The outcome
The refinance funded at $360,000, 75% loan-to-value, on a five-year fixed at 5.49%, qualifying payment $2,631, GDS 35.8% and TDS 39.8%. The full $150,000 landed in a single, segregated business account opened the same week, with nothing else ever deposited into it.
This is a conventional (uninsured) refinance, so CMHC's ratio ceilings do not bind directly; 39%/44% are shown as the lender's own applied policy, not an insurer's rule.
What to take from this file
- 01Interest deductibility turns on the use of borrowed money, not what secures it. A mortgage against a principal residence can fund fully deductible business interest, provided the proceeds genuinely go toward earning income.
- 02Tracing beats intention. CRA's own folio is built around whether borrowed money can be traced to its income-earning use — commingling it with other funds is what defeats a deduction, not the client's stated purpose.
- 03‘Cash damming’ is a real, named technique, not an invented workaround. Segregating borrowed funds into their own account, apart from every other dollar, is exactly what CRA's Income Tax Folio S3-F6-C1 describes as the way to keep a use traceable.
- 04Get the disbursement structure right at closing. A blended readvanceable facility or a deposit into an existing operating account can undo a deduction that a clean, segregated lump sum would have protected.
Sources
Every regulatory figure in this file traces to one of these primary sources. Client details and anything that varies by lender are illustrative, as flagged below.
- ▸OSFI — Minimum qualifying rate for uninsured mortgages — the minimum qualifying rate — greater of contract rate + 2% or 5.25%.
- ▸Provincial/territorial mortgage-broker legislation fetched directly (bclaws.gov.bc.ca, legisquebec.gouv.qc.ca, fcaa.gov.sk.ca, web2.gov.mb.ca, nslegislature.ca, assembly.nl.ca) plus FCNB's own site for NB and CanLII's index for PE — see notes for per-province method — provincial mortgage regulators and licence titles.
Illustrative in this file — lender-specific, not rules:
- ▸5.49% contract rate — rates move daily; not a quote.
- ▸39% GDS / 44% TDS shown for context — this is an uninsured conventional refinance, so these are the lender's own applied ceilings, not an insurer's rule.
- ▸$310 property tax / $150 heat estimates and the $340 vehicle loan — illustrative figures for this file.
Authority & provenance
How this case file was built
We publish the origin, the verification method and the reviewer for every case file, so you can judge how far to trust it before you rely on it with a client.
Where it comes from
Derived from files handled by Treadstone’s fulfillment desk and from scenarios contributed by partner brokerages. Names, employers, exact amounts and dates are changed so no client or file is identifiable.
Provenance: Composite — a pattern seen repeatedly on fulfilled files, not a single transaction.
What is verified
Every regulatory figure traces to a primary source listed above and was checked against it on the date shown. The arithmetic is recomputed by machine on every rebuild.
Anything that varies by lender is labelled illustrative rather than stated as a rule.
Who reviewed it
Reviewed for Canadian regulatory accuracy before publication, and re-checked whenever a cited rule changes.
Reviewed by: Nicholas Parson, Treadstone Associates — reviews every case file before publication.
This case file is professional reference material for licensed mortgage professionals. It is not advice to a borrower, and it is not a lender commitment. Insurer rules, qualifying rates and provincial taxes change — confirm the current position with the insurer, regulator or lender before you rely on any figure here in a live file.