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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 Corporation
BCM Cayman LP & Anor v Commissioners for His Majesty's Revenue and Customs, [2023] EWCA Civ 1179-- summary under Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Corporation UK LLP is a corporation In the course of finding that an unincorporated body (a Cayman LP) could not be a member of a UK LLP, Whipple LJ stated (at para. 47): 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 …. ...
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. ...
Technical Interpretation - Internal summary
13 June 2012 Internal T.I. 2012-0435351I7 F - SEPE - chèques en circulation -- summary under Payment & Receipt
13 June 2012 Internal T.I. 2012-0435351I7 F- SEPE- chèques en circulation-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in Quebec, payment by cheque does not occur until debiting of bank account Are the cash assets of Opco reduced by the amount of issued and outstanding cheques that have not yet been cashed? CRA responded: Under the civil law in force in Quebec, the delivery of an outstanding cheque does not constitute payment … [and] the date of payment of a debt settled by cheque is considered to be the date on which the cheque is honoured or paid by the bank …. [Here] the cheques in circulation and not yet cashed do not constitute payments of the amounts due to Opco's suppliers and … consequently, there can be no reduction in the amount of the cash of Opco as long as the bank does not honour or pay such cheques. ...
Technical Interpretation - External summary
18 September 2001 External T.I. 2001-0095265 F - TAXE SUR LE CAPITAL -- summary under Payment & Receipt
18 September 2001 External T.I. 2001-0095265 F- TAXE SUR LE CAPITAL-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in Quebec, a cheque is not payment until the debtor’s account is debited In indicating that outstanding cheques of a corporation do not represent loans or advances, CCRA stated: The delivery of a cheque (other than a certified cheque, money order or any other equivalent instrument) by a corporation governed by the Civil Code does not constitute a payment since, according to Article 1564 of the Civil Code, the payment transaction cannot be completed until the debtor's bank has actually paid the amount. … Consequently, the payment date is considered to be the date on which the cheque is honoured or discharged by the bank, which normally occurs … on the date on which the cheque in question is debited from the debtor's account. ...
Technical Interpretation - External summary
7 December 2010 External T.I. 2010-0363431E5 F - Date limite cotisation REER -- summary under Payment & Receipt
7 December 2010 External T.I. 2010-0363431E5 F- Date limite cotisation REER-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt RRSP premium “paid” when cheque received by issuer, not when it’s deposited In commenting on whether an RRSP premium is considered to have been paid within the first 60 days of a year, CRA stated: In general, we consider a premium to have been paid on or before the 60th day after the end of the calendar year if the RRSP issuer received a cheque for an RRSP contribution on or before the 60th day, and the date of the cheque is also on or before the 60th day. ...
Technical Interpretation - Internal summary
21 July 2009 Internal T.I. 2009-0322591I7 F - Déduction des intérêts -- summary under Payment & Receipt
21 July 2009 Internal T.I. 2009-0322591I7 F- Déduction des intérêts-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt replacement of note with capitalized note with note for full amount did not constitute payment by novation The taxpayer purchased assets from the vendor (apparently, a non-resident) in consideration for shares of the taxpayer and interest-bearing debt, that was evidenced by a note providing that unpaid interest could be added to the principal of the note. ...