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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. ...

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. ...

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. ...

9 May 2006 Internal T.I. 2006-0176371I7 F- Bourses d'études ou d'entretien-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt bursaries “received” by students even though required to be applied directly to their loans CRA found that bursaries paid to Quebec students under the Program québécois de prêts et bourses (the Quebec loans and bursaries program) by converting loans initially made to them into bursaries (following an ARQ verification of their income) that, thus, did not have to be repaid, were includible in income under s. 56(1)(n), subject to the exclusions under s. 56(3). ...

1 August 1996 External T.I. 9604555- AMOUNT PAYABLE SUBSECTION 104(24)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note normally only constitutes an enforceable right to the income where it is payable on demand Regarding whether a mutual fund trust beneficiary had a legal entitlement to the income of the trust where a promissory note for the income amount was issued to the beneficiary, RC stated: [O]rdinarily a promissory note is given and received as acknowledgement of the existence of and/or the conditional payment of a debt and does not itself create the debt. ...

24 May 2002 Internal T.I. 2002-0130667 F- REGIME PRESTATION EMPLOYES-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amounts “received” under EBP if unrestricted right to receive Under a provision of an employee benefit plan which was assumed, for discussion purposes, to be grandfathered from the salary deferral arrangement rules, an employee could elect at the time of retirement to receive all amounts accumulated in the plan either immediately or in instalments (through the purchase of an annuity). ...

2021 Ruling 2021-0876671R3- Transfer between US pension plans-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no constructive receipt to Canadian beneficiaries where the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan S. 56(1)(a) generally requires the recognition of an amount received as or in satisfaction of a pension benefit. ...

15 March 2019 External T.I. 2018-0766021E5- Obligation to prepare T4A slips-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt the payer is the person who has discretion and control over the funds A Canadian university agreed with a (perhaps, foreign) Ministry to apply funding received by it to pay the tuition of and a monthly stipend to trainees who were accepted into a University program. ...

7 November 2022 External T.I. 2022-0926091E5- Transfer of UK DB pension benefits to a UK SIPP-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt doctrine applied to direct payment from one UK pension plan to UK individual pension plan After a UK resident (under age 55) became resident in Canada, the commuted value of the individual’s member benefits under a UK defined-benefit pension plan was transferred directly to a UK self-invested personal pension plan (SIPP) of which the individual was the sole beneficiary. ...

2023 Ruling 2023-0964601R3- Loss consolidation arrangement-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in-house re-circulating daylight loan used to fund a loss-shifting transaction CRA ruled on routine transactions between two Lossco subsidiaries and one Profitco subsidiary of an immediate Canadian parent company involving Lossco loans to the Profitco and Profitco subscriptions for Lossco cumulative preferred shares. ...