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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. ...

The Queen, 2009 DTC 687, 2009 TCC 190-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development The taxpayer in carrying out work largely under the supervision of a researcher who was not its employee or representative, and in testing the effectiveness of products that had already been commercially developed, did not qualify for deduction as SR&ED. ...

The Queen, 2005 DTC 457, 2004 TCC 341-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Work carried out by the taxpayers to improve the performance of a tactometer represented "routine techniques and standard procedures generally accessible to competent professionals in the field" (p. 461), and did not qualify as SR&ED. ...

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. ...

MNR, 93 DTC 451, [1993] 1 CTC 2710 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development A supposed research project which folded after the initial phases of work and therefore consisted only of routine data collection and research in the educational area did not qualify as scientific research described in Regulation 2900. ...

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. ...

MNR, 92 DTC 1036, [1992] 1 CTC 2136 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Christie A.C.J. accepted the evidence of the Crown's scientific expert that the proposed research program of the taxpayer was not carried out in any systematic, scientific manner and that the principals involved had no work experience in the central areas of the project. ...

., 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. ...