Payment & Receipt

loan owed by taxpayer to FA2 not repaid on winding up of FA2 into FA1, but was then repaid by set-off

Quebec debtor has the right to determine which advance a repayment should be applied to

payment of top-up amount could be “paid” through providing additional vacation days

embedded royalty reduction was not an amount received

payment by partnership of withholding tax treated as a distribution to its partners

daylight loan circled 4 times

there can be no payment by direction unless there is an antecedent obligation by the creditor to the third party

in Quebec, a cheque is not payment until the debtor’s account is debited

in-house re-circulating daylight loan used to fund a loss-shifting transaction

salary paid into her husband’s bank account was constructively received by the employee