Search - 包建铎违纪违法案件以案促改以案促治专题组织生活会 个人对照检查

25 March 2009 External T.I. 2008-0300401E5 F- Fiducie en faveur de soi-même- prêt sans intérêt-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt individual pays trust taxes when he receives trust distributions net of such taxes CRA indicated that an individual would be considered to be personally paying taxes of a trust that had made a s. 104(13.1) where he received distributions from the trust net of such taxes. ...

29 April 2003 External T.I. 2002-0177065 F- CONFISCATION DE LA SOLDE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt forfeited salary nonetheless includible as salary received CCRA indicated that salary that was forfeited by RCMP officer for misconduct nonetheless was to be treated as includible in the officer’s income as salary which was to be treated as having been received by the individual before its forfeiture as a fine. ...

4 July 2011 External T.I. 2011-0401991E5 F- CDA and life insurance proceeds-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Insurance proceeds received by borrower where applied to repay its loan CRA stated: In factual situations similar to the Innovative Installation case, the CRA will apply the position adopted by the Court in that case. Consequently, in a situation where a corporation can demonstrate that life insurance proceeds that were paid directly to a financial institution have reduced its debt to the financial institution, the life insurance proceeds will be considered as "received" by that corporation for the purpose of applying subparagraph (d)(ii) of the definition of CDA …. ...

26 November 1992 T.I. 923506 (September 1993 Access Letter, p. 411, ¶C20-1161)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt For farmers on the cash method, a post-dated cheque that is received on a date that a debt owing to the taxpayer is not yet payable will be brought into income on the earlier of the date the debt becomes payable and the date the cheque is negotiated. ...

11 December 2013 External T.I. 2013-0474161E5- T-slips and dividend and interest-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt Respecting a question as to when dividends are paid and received for T5 purposes, CRA stated: In Innovative Installation Inc. v The Queen, 2009 TCC 580, the Tax Court of Canada explained that "received" does not require "proceeds to pass directly to the taxpayer. ...

6 November 2012 External T.I. 2012-0452531E5- Satisfactory Evidence of Payment-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note accepted as payment In response to a question as to whether "a demand note payable, which is accepted as absolute payment of salary owing to an employee, constitutes satisfactory evidence of the payment of that salary," CRA stated: An ordinary promissory note is generally regarded as a promise to pay a debt at a later date, and not as payment of the debt on the date on which the note was issued. ...

17 June 2014 External T.I. 2013-0506731E5- Immigration-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt note satisfied dividend An individual shareholder immigrates to Canada, thereby becoming a Canadian resident. ...

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. ...

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. ...

18 September 2001 External T.I. 2001-0095265 F- TAXE SUR LE CAPITAL-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in Quebec, a cheque is not payment until the debtor’s account is debited In indicating that outstanding cheques of a corporation do not represent loans or advances, CCRA stated: The delivery of a cheque (other than a certified cheque, money order or any other equivalent instrument) by a corporation governed by the Civil Code does not constitute a payment since, according to Article 1564 of the Civil Code, the payment transaction cannot be completed until the debtor's bank has actually paid the amount. … Consequently, the payment date is considered to be the date on which the cheque is honoured or discharged by the bank, which normally occurs … on the date on which the cheque in question is debited from the debtor's account. ...