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The Queen, 2005 DTC 585, 2005 TCC 216 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payments in kind Bell J. rejected the Crown's submission that the taxpayer can only make a deduction under s. 8(1)(i) for amounts paid in cash or by cheque with proof of payment, and found that the taxpayer was entitled to a deduction under s. 8(1)(I)(ii) for snowmobiles, motorcycles and gasoline that he had purchased for his sons as payment for their services in performing mailings to 2,500 people on five different occasions in the year. ...

MNR, 70 DTC 6333, [1970] CTC 510 (Ex Ct), briefly aff'd 71 DTC 5217 (SCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt interest coupons required to be presented An individual following the cash method for the recognition of interest income received interest represented by interest coupons on the due dates. ...

The Queen, 2009 DTC 912, 2009 TCC 295-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no evidence of payment through off-settable cash Promissory notes owing by the taxpayers, which were consideration for their acquisition of units of a limited partnership, provided that the interest thereon was to be paid by way of set-off against distributions otherwise payable by the partnership to the taxpayers. ...

., 2005 DTC 5150, 2004 BCSC 604-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission As the common intention of the parties to agreements respecting the production of a movie was that it would be eligible for the federal film or video production services tax credit and the equivalent BC income tax credit, the court agreed to a rectification of the agreements to reflect a different party as the holder of the copyright. ...

The Queen, 2009 DTC 1388 [at at 2135], 2009 TCC 580, aff'd supra-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt when payment to creditor After noting (at para. 21) that "the case law is clear that an amount may be included in income even where it is only notionally or constructively received", McArthur, J. went on to find that the taxpayer had received insurance policies under a policy that had been assigned by it to a bank given that it benefited from the insurance proceeds being applied to pay off a loan owing by it to the bank. ...

Minister of Finance, 2008 CanLII 15226 (Ont SCJ), briefly aff'd 2009 ONCA 715-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission In a property tax dispute, counsel moved to couple the taxpayer's appeal with a rectification application, so that the rectification would serve as an alternative if the main appeal failed. ...

The Queen, 2007 DTC 263, 2006 TCC 677-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment by demand loan t was found that bonuses declared payable by the taxpayer to its two directors were paid by it within the 180 day period referred to in s. 78(4) pursuant to a demand loan agreement (notwithstanding that the directors did not report the portion of the demand loan that was not paid in cash until the subsequent year as employment income until that subsequent year). ...

The Queen, 95 DTC 749, [1996] 1 CTC 2105 (TCC) (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment in kind if agreement as to the amount The taxpayer transferred his equity in a house to his former spouse in satisfaction of arrears of alimony or maintenance owing to her of $19,946. ...

MNR, 93 DTC 5295 (FCA)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment when cheque accepted as payment Interest owing to the taxpayer as a result of the acceptance by his co-shareholders of his offer to sell his shares in a corporation, was found to be received by him at the end of 1990, when he accepted the related cheque as payment (as evidenced by his deposit of the cheque at a branch of his bank that, unlike his local branch, was open that day), rather than early in 1991 when the amount was credited by the bank to his account at the local branch. ...

The Queen, 2015 DTC 1013 [at at 64], 2014 TCC 334-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payments not received where children "recipients" had no control over funds Purported distributions out of a purported EPSP to children employees of the taxpayer were to a bank account controlled by the father, so that the participants "never had control of these funds" (para. 40), and so that the "real transactions" were "the payment of amounts by the corporation to the father" (para. 42). ...