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16 March 2015 Internal T.I. 2013-0479861I7- Section 116 & forfeited deposits on real property-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (b) forfeited sale deposit was proceeds Before finding that a deposit forfeited to a non-resident vendor under an agreement for sale of B.C. real property (due to failure of the purchaser to close) did not represent proceeds of taxable Canadian property by virtue of s. 248(4), CRA first stated (based on the s. 248(1) – "disposition" definition) that "there is a disposition of a right under a contract where an agreement of sale has been cancelled and the buyer's deposit is forfeited to the vendor," ...

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 16, 2017-0705181C6 F- Hedging & George Weston Limited-- summary under Futures/Forwards/Hedges Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. Profit- Futures/Forwards/Hedges CRA is considering changing its policy re what is capital hedge After noting that “the CRA has already stated that it accepts the decision … in George Weston,” CRA noted, however, that: The approach taken by the TCC in [MacDonald] respecting, inter alia, the linkage principle appears to be irreconcilable with previous jurisprudence, including George Weston Limited.... ...

-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt of cheque (that is not subsequently dishonoured) is payment at that time A payment by cheque is equivalent to a payment in cash as long as no special circumstances lead to another conclusion, and the cheque is not dishonoured on presentation for payment. ...

5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 10, 2018-0761551C6 F- Attribution rules and promissory note-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note could not be issued as payment in context of income attribution rules Where a loan is made to a spouse at the prescribed interest rate, s. 74.5(2) requires that each year’s interest be “paid” by January 30 of the following year. ...

17 February 2004 External T.I. 2003-0033915- Cash pooling- shareholder benefit-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no automatic set-off In indicating that a cash pooling arrangement entered into by a Canadian subsidiary with its non-resident parent corporation could result in an income inclusion under s. 15(2), Revenue Canada indicated that its review of the jurisprudence on s. 15(2) suggested that debts between a shareholder and a particular corporation do not generally offset for purposes of determining either whether the shareholder became indebted to the corporation in the first place, or whether that indebtedness has been repaid. ...

14 May 2019 CLHIA Roundtable Q. 3, 2019-0799111C6- 2019 CLHIA Q3- 3rd party RRSP contributions-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment at direction of annuitant is payment by annuitant CRA indicated that it is acceptable for an RRSP contribution to be received from a third party (i.e., drawn on a bank account other than the annuitant’s) “provided that the payment is made at the direction or with the concurrence of the annuitant of the RRSP,” so that the RRSP receipt should be issued by the financial institution to the annuitant. ...

29 March 2021 Internal T.I. 2020-0865791I7- CEWS- eligible remuneration-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt remuneration not considered to be paid by journal entry The CEWS (wage subsidy) is generated based on the amounts of “eligible remuneration paid to the eligible employee.” ...

2023 Ruling 2023-0973911R3- Loss Consolidation Ruling-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt daylight loan circled 4 times CRA ruled on a triangular loss-shifting transaction between Lossco and its subsidiary, Profitco, under which Lossco used a daylight loan to make an interest-bearing loan (pursuant to the “IB Note”) to Profitco, who subscribed for preferred shares of its sister, “Numberco,” who made a non-interest-bearing loan to Lossco. ...

10 April 2024 External T.I. 2021-0919231E5- Foreign tax allocation to a partner-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment by partnership of withholding tax treated as a distribution to its partners Regarding the allocation of foreign tax by a partnership to a partner, CRA stated: If the partnership pays the foreign tax on behalf of the partner or the foreign tax is withheld on behalf of the partner in accordance with foreign law from the foreign income paid to the partnership, such amount would be considered [for purposes of s. 53(2)(c)(v)] to be received by the partner on account or in lieu of payment of, or in satisfaction of, a distribution of the partner’s share of the partnership profits or partnership capital. ...

14 May 2015 CLHIA Roundtable, 2015-0573841C6- 2015 CLHIA Roundtable – Winding-up and ACB-- summary under Subsection 148(7) Summary Under Tax Topics- Income Tax Act- Section 148- Subsection 148(7) s. 69(5) generally prevails over s. 148(7) At the 2005 CALU Roundtable (2005-0116631C6), the CRA indicated that s. 69(5) would likely take precedence over s. 148(7) on the wind-up of a corporation under s. 88(2), so that a distributed interest in a life insurance policy would be disposed of at fair market value rather than cash surrender value. In confirming that this position "remains unchanged," CRA stated: [T]he general rule is that where two provisions in the same statute conflict, the more specific provision should take precedence. … While we would generally expect subsection 69(5) to take precedence over subsection 148(7)… this approach is subject to a review of the particular facts and circumstances of an actual case…. ...