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., 2010 DTC 5175 [at at 7317], 2010 FCA 285-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt indirect receipt through debt repayment In order to ensure payment of a loan owing by the taxpayer ("Innovative") to a bank (RBC) on the death of Innovative's principal (Mr Peacock), Innovative purchased key man insurance from Sun Life with RBC as the policyholder and funded the payment of premiums on the policy. ...

Canada, 2003 DTC 5715, 2003 FCA 423-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt application of payment by creditor The quantum of the taxpayer's liability under s. 160 turned upon whether a bankruptcy dividend received by the Crown from the trustee in bankruptcy for her husband should be considered to reduce the tax liability of her husband at the time he made contributions to her RRSP rather than being applied to more recent tax liabilities. ...

., 74 DTC 6104, [1974] CTC 101 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt of sums collected by affiliate The taxpayer, which operated a boat storage business in a storage building, subleased a portion of the leased premises to an affiliate ("Georgia") with accumulated losses, but continued to operate the business the same as before. ...

MNR, 90 DTC 1375, [1990] 1 CTC 2539 (TCC), aff'd 92 DTC 6223 (FCTD), briefly aff'd in turn at 94 DTC 6261 (FCA)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission must give effect to agreement In refusing to recognize a price rectification agreement, Sarchuk, J. stated (p. 1378): "Rectification is an 'equitable remedy' whereby one party to a contract seeks the court's intervention to rectify a written instrument which does not accurately reflect the terms agreed to orally by the parties prior to putting their agreement down in writing... the remedy of rectification is not available to correct a mistaken assumption of fact. ...

The Queen, 2003 DTC 1410, 2003 TCC 674 (Informal Procedure)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Various efforts made by the taxpayer to improve the accuracy of a freight weighing device did not qualify given that there was "some merit" in the Crown expert's contention that the manner in which the taxpayer proceeded was akin to the use of routine or standard engineering practices, it was difficult to understand what hypothesis, if any, was made and what steps were being proposed to eliminate the technological uncertainty if one existed, and virtually no records were kept of any hypotheses tested and of results as the work progressed. ...

.)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt issuance of debt certificates not payment An American corporation passed a resolution providing "'that a distribution of seven per cent on the capital stock of this corporation, amounting to $52,500 dollars, be and the same is hereby declared, payable on the 15th December, 1936'" and went on to provide that the distribution should not be payable in cash, but in the form of certificates of indebtedness bearing interest at 4%, and payable approximately four years later. ...

The Queen, 2011 DTC 1065 [at at 346], 2011 TCC 41, 2012 TCC 65-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt bonus booked as loan back/constructive receipt The individual taxpayer was found to have received a bonus from a closely-held corporation in the year that the corporation declared the bonus rather than in the subsequent year of payment in light of the withholding and remittance of source deductions on the full amount of the bonus in the first year, the booking by by the corporation in that year of a loan back to it of the net bonus proceeds and the absence of any evidence that this was done without his knowledge or consent. ...

.)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The taxpayers were incorporating shareholders of a corporation. ...

.)-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission A Newfoundland corporation was amalgamated with what was thought to be a wholly-owned subsidiary in a short-form amalgamation. ...

., 98 DTC 1839, [1998] 3 CTC 2520 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development 5 factors test The taxpayer was an engineering consultant firm that specialized in the development, management and protection of water resources. ...