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25 June 2002 Internal T.I. 2002-0130177 F- DEBENTURE CONVERTIBLE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Teleglobe applied to find that amount paid by corporation on conversion of convertible debentures was the shares’ stated capital CCRA reviewed the line of cases culminating in Teleglobe, and concluded that the amount paid by the issuer on the conversion of its convertible debentures should be treated as the stated capital of the shares issued, which equaled the face amount of the converted debentures. ...

2021 Ruling 2021-0911211R3- Foreign Takeover-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt borrowing and payment of funds pursuant to an internal payment direction agreement CRA ruled on transactions which included the borrowing of money by a newly-formed non-resident corporation (Merger Sub1) from a Canadian affiliate (Opco) and its advance of such funds to a transfer agent for shareholders of a non-resident target (Target), pursuant to directions in an internal funding agreement. ...

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 …. ...

-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note accepted as absolute payment for the transfer of s. 28 inventory In finding that a cash-basis farmer realized income on the transfer of inventory for a promissory note, CRA stated: Since the promissory note was accepted as consideration for the transfer of the inventory, and given that none of the documents provide any remedy for non-payment, it appears that payment could only be enforced under the terms of the promissory note. Therefore, on the basis of the documents submitted, it is our view that the promissory note constitutes absolute payment …. ...

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. ...

-- 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. ...