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7 October 2013 Internal T.I. 2013-0504081I7 F- Interaction between 55(2) and 40(1)(a)(iii)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt distinction between promissory note as conditional or absolute payment Vendor sold blocks of shares in the capital of a corporation (the “Purchaser”) to the Purchaser, with the purchase price being payable over a following number of years based a percentage in each year of the annual consolidated after-tax profits of the Purchaser. ...

30 January 2014 External T.I. 2013-0515761E5 F- Dividend received-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt book entries merely record and do not establish that a dividend was paid A dividend of a taxable Canadian corporation owned by an individual is not paid in money but is recorded in its books as an increase in a loan owing to the shareholder or as a decrease in a loan made to the shareholder. ...

30 March 2011 External T.I. 2010-0390591E5 F- Cotisation spéciale-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amounts paid by set-off are both paid even though no movement of funds All the condo owners in a condo complex that was used only in a high-end commercial accommodation business leased their units to a manager for a share equalling 50% of the aggregate rental income (but with the municipal taxes and condominium fees for common services continuing to be borne by the co-owners directly). ...

4 October 2002 Internal T.I. 2001-010564A F- PENSION ALIMENTAIRE-ARRERAGES-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt set-off does not constitute payment unless the parties so agree After finding that a lump-sum payment to cover support-payment arrears could be considered as an amount payable on a periodic basis, even though it was less than the amount initially anticipated, the Directorate went on to note: The Court of Appeal judge decided to credit the amount of $XXXXXXXXXX, which consisted of expenses incurred by Monsieur for the benefit of the child, against the balance of the arrears owed to Madame by Monsieur. ...

13 August 2020 External T.I. 2019-0802891E5 F- Unclaimed RRSP Benefits-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt of amount deducted on account of fees that were the recipient’s obligation The estate of the deceased annuitant of an RRSP was fully settled without the executor (his surviving wife and the sole beneficiary) being aware of the RRSP. ...

15 November 2002 Internal T.I. 2002-0162427 F- Price Adjustment Clause & 85(7.1)-- summary under Effective Date Summary Under Tax Topics- General Concepts- Effective Date large FMV discrepancy suggested lack of bona fide valuation so that price adjustment clause need not be applied/ if applied, s. 85(1) election must be amended Madame exchanged her Class A shares of the corporation for Class D shares having a redemption amount which CCRA subsequently determined was substantially less than the FMV of the Class A shares, and filed a s. 85(1) rollover election respecting this exchange. ... The jurisprudence has shown that a price adjustment clause can be ignored in cases where there is no good faith effort to determine the FMV of a property (See: Guilder News ….). On this basis, it seems to us that you would be free to ignore the price adjustment clause and therefore maintain an assessment under 85(1)(e.2). … [If] you decide to recognize the price adjustment clause … the taxpayer must file an amended election to give effect to the price adjustment clause. ...

2 April 2019 Internal T.I. 2016-0649821I7 F- Unclaimed superannuation or pension benefits-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amount received in Year 2 in lieu of pension benefit includes source deductions in Year 1 Although CRA usually applies its constructive receipt concepts in the context of employment income recognition, it has applied that concept to pension income recognition under s. 56(1)(a)(i). ... Its reasoning was that the amount could not be considered to be “received” as a pension benefit in the year of payment by the RPP administrator to the Directorate because the right-holder had not yet been identified – whereas in the subsequent year of payment over by the Directorate to the right-holder, that right-holder is receiving that amount under s. 56(1)(a)(i) as being “in lieu of” a superannuation or pension benefit. ...

2018 Ruling 2018-0740931R3 F- deductibility of interest – convertible debentures-- summary under Subsection 20(3) Summary Under Tax Topics- Income Tax Act- Section 20- Subsection 20(3) s. 20(3) applicable to borrowed money used to redeem principal of convertible debentures A Canadian public company (ACo) will force the conversion of its outstanding convertible debentures, by issuing a notice to redeem them for their principal amount. ... It also ruled: Subsection 20(3) will be applicable to the portion of Loan 3 … corresponding to the aggregate principal amount of the outstanding Debentures … such that borrowed money will be deemed for purposes of the application of paragraph 20(1)(c) to be used for the purposes for which the outstanding Debentures were used or incurred. ...

19 November 2012 External T.I. 2012-0459351E5- Shale Gas Well Drilling Classification-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development In considering the conditions under which a shale gas well would qualify for Canadian development expense credits, CRA noted that drilling the well may qualify for scientific research and experimental development credits if done for "experimental development of a new technology. ...

8 June 2018 Internal T.I. 2018-0744881I7- Regulation 403 – allocation of income-- summary under Subsection 403(3) Summary Under Tax Topics- Income Tax Regulations- Regulation 403- Subsection 403(3) PE for 403(3) purposes includes any PE of any partnership of which insurer is member An insurance corporation (that reinsures policies issued by another insurer) holds partnership interests in several partnerships that have no insurance business and have permanent establishments in other provinces, but are not involved in an insurance business. ... Consequently … the taxpayer will have a PE in any province where the partnerships have a PE. … [B]ased on the fact that the taxpayer derives income (premiums) from reinsuring property situated in a province where the taxpayer has a PE due to being a member of a partnership, subsection 403(1) of the Regulations will allocate the taxpayer’s taxable income on a proportional basis to that province. … In view of the taxpayer having a PE in the province(s) where the partnerships have a PE, subsection 403(3) does not apply to the taxpayer with respect to those provinces. ...