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He concluded that such single supply was a taxable supply, stating: … I find that [the cardholders] … paid the surcharge fee to Access for arranging for the transfer of money, not to the Appellant for transferring the money. … Access benefited from having the Appellant transfer the money. ... This was the predominant element of the supply it received …. … [T]he predominant element of the single compound supply made in the Subsequent Periods was the exclusive right to place and operate ATMs at the Resort and to process all transactions arising therefrom. ... The Queen, 2022 TCC 45 under ETA s. 123(1) – financial service – (a). ...
Old website (cra-arc.gc.ca)
T2 Corporation – Income Tax Guide – 2016
T2 Corporation – Income Tax Guide – 2016 T4012(E) Rev. 16 If you are blind or partially sighted, you can get our publications in braille, large print, etext, or MP3 by going to About multiple formats. ... La version française de ce guide est intitulée Guide T2 – Déclaration de revenus des sociétés. ... Before you start Chapter 1 – Page 1 of the T2 return Identification Chapter 2 – Page 2 of the T2 return Attachments Information schedules and forms Calculation schedules Chapter 3 – Page 3 of the T2 return Attachments Additional information Calculating net income or loss Losses How to complete Schedule 4, Corporation Loss Continuity and Application Taxable income Chapter 4 – Page 4 of the T2 return Small business deduction Chapter 5 – Page 5 of the T2 return General tax reduction Chapter 6 – Pages 6 and 7 of the T2 return Refundable portion of Part I tax Refundable dividend tax on hand Dividend refund Chapter 7 – Page 8 of the T2 return Part I tax Chapter 8 – Page 9 of the T2 return Summary of tax and credits Federal tax Provincial and territorial tax Other credits Refund or payment Payment of balance owing Direct deposit request Mandatory electronic filing for tax preparers Certification Language of correspondence Related forms and publications List of federal and provincial or territorial corporation schedules and forms Online services Handling business taxes online Electronic payments For more information What if you need help? ...
Decision summary
Minsham Properties Ltd. v. Price, [1990] BTC 528 (Ch. D.) -- summary under Payment & Receipt
.)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt mere addition of accrued interest not payment Although "there can be no doubt that a book entry can constitute payment" (p. 540), in the case of an informal loan from the taxpayer's parent corporation to the taxpayer, the mere addition of accrued interest to the principal owing by the taxpayer to the parent did not constitute payment. ...
EC summary
Robwaral Ltd. v. MNR, 60 DTC 1025, [1960] CTC 16 (Ex Ct), briefly aff'd 64 DTC 5266 (SCC) -- summary under Payment & Receipt
MNR, 60 DTC 1025, [1960] CTC 16 (Ex Ct), briefly aff'd 64 DTC 5266 (SCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt dividend not received until cheque received A dividend was "received" by a shareholder in the year in which the cheque was drawn and received by him, rather than in the previous year in which the dividend was declared and in which the record date occurred. ...
Decision summary
Downtown King West Development Corp. v. Massey Ferguson Industries Ltd. (1993), 14 OR (3d) 528 (Ont Ct GD) -- summary under Rectification & Rescission
Massey Ferguson Industries Ltd. (1993), 14 OR (3d) 528 (Ont Ct GD)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission Given that a lease as signed did not reflect the terms agreed to in the letter of intent and that a change to the terms of a right of first refusal was never discussed with the party whom such change might adversely affect, this was found to be an appropriate case for rectification. ...
Decision summary
Re Charge Card Services Ltd., [1988] 3 All E.R. 702 (C.A.) -- summary under Payment & Receipt
.)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt card acceptance was payment A company issued charge cards to cardholders who would obtain petrol from garages by presenting the card and signing a sales voucher completed by the garage. ...
FCA (summary)
Canada v. Gillette Canada Inc., 2003 DTC 5078, 2003 FCA 22 -- summary under Payment & Receipt
., 2003 DTC 5078, 2003 FCA 22-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt replacement with different currency note The replacement of a French-franc note by a Canadian-dollar note with an equivalent principal amount did not give rise to a payment or crediting for purposes of s. 212(13.1)(b) given that the Canadian-dollar note was issued and accepted as replacement for the French-franc note in circumstances where the terms remained the same except for the currency of payment. ...
TCC (summary)
M. Soutar Decor 2000 Ltd. v. The Queen, 2016 TCC 62 (Informal Procedure) -- summary under Payment & Receipt
The Queen, 2016 TCC 62 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt seizure of a guarantor’s security constituted a transfer Bocock J found that when a bank seized the security (a GIC) provided by a tax debtor to secure his guarantee of a bank loan to his son’s company, this constituted a transfer of property by him to that company for s. 160 purposes. ...
TCC (summary)
Foster v. The Queen, 2016 DTC 1010 [at 2562], 2015 TCC 334 -- summary under Rectification & Rescission
The Queen, 2016 DTC 1010 [at 2562], 2015 TCC 334-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission consequential reassessment permitted under s. 152(5) Paris J found that, although a rectification order replaced a series of sales of a fishing licence and equipment with a different series of sales, both series dealt with the same "amounts" for the purpose of s. 152(5). ...
Current CRA website
T2 Corporation – Income Tax Guide – 2020
T2 Corporation – Income Tax Guide – 2020 From: Canada Revenue Agency T4012(E) Rev. 20 Our publications and personalized correspondence are available in braille, large print, etext, or MP3 for those who have a visual impairment. ... La version française de ce guide est intitulée Guide T2 – Déclaration de revenus des sociétés. ... Before you start Chapter 1 – Page 1 of the T2 return Identification Chapter 2 – Page 2 of the T2 return Attachments Information schedules and forms Calculation schedules Chapter 3 – Page 3 of the T2 return Attachments Additional information Calculating net income or loss Losses How to complete Schedule 4, Corporation Loss Continuity and Application Taxable income Chapter 4 – Page 4 of the T2 return Small business deduction Chapter 5 – Page 5 of the T2 return General tax reduction Chapter 6 – Pages 6 and 7 of the T2 return Refundable portion of Part I tax Refundable dividend tax on hand Dividend refund Chapter 7 – Page 8 of the T2 return Part I tax Chapter 8 – Page 9 of the T2 return Summary of tax and credits Federal tax Provincial and territorial tax Other credits Refund or payment Payment of balance owing Direct deposit request Mandatory electronic filing for tax preparers Certification Language of correspondence Related forms and publications List of federal and provincial or territorial corporation schedules and forms Digital services Handling business taxes online Electronic payments For more information What if you need help? ...