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Technical Interpretation - Internal summary
30 June 1995 Internal T.I. 9503907 - TAX STATUS OF CHEQUE RETURNED BY CASH METHOD FARMER? -- summary under Payment & Receipt
-- 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. ...
Conference summary
5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 10, 2018-0761551C6 F - Attribution rules and promissory note -- summary under Payment & Receipt
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. ...
Technical Interpretation - External summary
17 February 2004 External T.I. 2003-0033915 - Cash pooling - shareholder benefit -- summary under Payment & Receipt
17 February 2004 External T.I. 2003-0033915- Cash pooling- shareholder benefit-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no automatic set-off In indicating that a cash pooling arrangement entered into by a Canadian subsidiary with its non-resident parent corporation could result in an income inclusion under s. 15(2), Revenue Canada indicated that its review of the jurisprudence on s. 15(2) suggested that debts between a shareholder and a particular corporation do not generally offset for purposes of determining either whether the shareholder became indebted to the corporation in the first place, or whether that indebtedness has been repaid. ...
Conference summary
14 May 2019 CLHIA Roundtable Q. 3, 2019-0799111C6 - 2019 CLHIA Q3 - 3rd party RRSP contributions -- summary under Payment & Receipt
14 May 2019 CLHIA Roundtable Q. 3, 2019-0799111C6- 2019 CLHIA Q3- 3rd party RRSP contributions-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment at direction of annuitant is payment by annuitant CRA indicated that it is acceptable for an RRSP contribution to be received from a third party (i.e., drawn on a bank account other than the annuitant’s) “provided that the payment is made at the direction or with the concurrence of the annuitant of the RRSP,” so that the RRSP receipt should be issued by the financial institution to the annuitant. ...
Technical Interpretation - Internal summary
29 March 2021 Internal T.I. 2020-0865791I7 - CEWS - eligible remuneration -- summary under Payment & Receipt
29 March 2021 Internal T.I. 2020-0865791I7- CEWS- eligible remuneration-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt remuneration not considered to be paid by journal entry The CEWS (wage subsidy) is generated based on the amounts of “eligible remuneration paid to the eligible employee.” ...
Ruling summary
2023 Ruling 2023-0973911R3 - Loss Consolidation Ruling -- summary under Payment & Receipt
2023 Ruling 2023-0973911R3- Loss Consolidation Ruling-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt daylight loan circled 4 times CRA ruled on a triangular loss-shifting transaction between Lossco and its subsidiary, Profitco, under which Lossco used a daylight loan to make an interest-bearing loan (pursuant to the “IB Note”) to Profitco, who subscribed for preferred shares of its sister, “Numberco,” who made a non-interest-bearing loan to Lossco. ...
Technical Interpretation - External summary
10 April 2024 External T.I. 2021-0919231E5 - Foreign tax allocation to a partner -- summary under Payment & Receipt
10 April 2024 External T.I. 2021-0919231E5- Foreign tax allocation to a partner-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment by partnership of withholding tax treated as a distribution to its partners Regarding the allocation of foreign tax by a partnership to a partner, CRA stated: If the partnership pays the foreign tax on behalf of the partner or the foreign tax is withheld on behalf of the partner in accordance with foreign law from the foreign income paid to the partnership, such amount would be considered [for purposes of s. 53(2)(c)(v)] to be received by the partner on account or in lieu of payment of, or in satisfaction of, a distribution of the partner’s share of the partnership profits or partnership capital. ...
Decision summary
BCM Cayman LP & Anor v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 1179 -- summary under Subsection 102(2)
BCM Cayman LP & Anor v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 1179-- summary under Subsection 102(2) Summary Under Tax Topics- Income Tax Act- 101-110- Section 102- Subsection 102(2) a two-tier partnership structure can be legally respected as such if the upper-tier partnership is a limited partnership The taxpayer (“Cayman Ltd.”) was a Cayman company which was the general partner of a Cayman LP (“Cayman LP”). ... He was not considering the position of limited partners in a limited partnership, whose role is limited and circumscribed by statute. … Cayman LP's business was carried on by its general partner (Cayman Ltd) and … the limited partners (including Fyled) were prohibited by Cayman law from taking part in Cayman LP's business …. ... A further basis for finding that Fyled was not a member of the UK LLP was that Cayman LP could not (and was not) recorded as a member of the UK LLP, nor was Fyled (para. 47): In any event, UK LLP is a UK corporate body governed by the Limited Liability Partnership Act 2000 which imposes a number of requirements, including … the requirement that members must subscribe their name to the incorporation document …. ...
FCA (summary)
R I S - Christie Ltd. v. Canada, 99 DTC 5087, [1999] 1 CTC 132 (FCA) -- summary under Scientific Research & Experimental Development
Canada, 99 DTC 5087, [1999] 1 CTC 132 (FCA)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer was entitled to have its expenditures treated as SR&ED notwithstanding the absence of documentary evidence relating to the repeatability of the testing data. ...
Decision summary
Fairmont Hotels Inc. v. A.G. Canada, 2014 ONSC 7302, aff'd supra, rev'd 2016 SCC 56 -- summary under Rectification & Rescission
Canada, 2014 ONSC 7302, aff'd supra, rev'd 2016 SCC 56-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission continuing non-specific intention to maintain a tax neutral structure In order to facilitate the acquisition in 2002 of a hotel in Washington by a REIT ("Legacy") of which it was the manager, Fairmont Hotels Inc. ... As he was bound by Juliar, he did not have the "luxury" of following Graymar and, in any event, he did not think that Brown J in that case "has accurately described what happened in Juliar " (para. 41). ...