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The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt past services Margeson J. accepted (at para. 99) that employees to whom the taxpayer issued shares in payment of bonuses to them gave consideration equal to the full value of those share "on the basis of past unremunerated services rendered to the Appellant. ...

The Queen, 2010 DTC 1213 [at at 3568], 2010 TCC 321 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt frequent flyer points Frequent flyer points applied by the taxpayer to purchase air tickets to Chicago for medical treatment there constituted "an amount paid" for purposes of s. 118.2(2)(g). ...

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. ...

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). ...

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. ...

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. ...

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. ...

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. ...

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). ...