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.)-- 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. ...

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. ...

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. ...

.)-- 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. ...

., 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. ...

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). ...

MNR, 92 DTC 1497 (TCC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment references funds transfer A taxpayer was ordered in 1984 to retain arrears of alimentary allowance that had accumulated from March 1983 onward to be applied against an amount owing to him by his estranged wife. In finding that the alimentary allowance was not "paid" by him for purposes of s. 60(b), and was not "received" by her for purposes of s. 56(1)(b), Garon J. stated (p. 1499): "... ...

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. ...