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18 November 2004 Internal T.I. 2004-0083251I7- Management Fees-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission General discussion of the distinction between rectification of mistakes and retroactive tax planning. ...

28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A taxpayer is not considered to have "paid" interest on a loan owing by him to a charitable foundation by virtue only of journal entries being recorded in his ledgers and those of the foundation. ...

15 June 1992 T.I. 921368 (December 1992 Access Letter, p. 18, ¶C56-208)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt No payment will be considered to occur pursuant to an agreement between the parties to the effect that interest on a promissory note will be deemed to be paid and then loaned back to the borrower. ...

"Patronage Dividends Paid by Non Co-ops")-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Payment of a patronage dividend may be effected by the issuance of shares or debt instruments, where such an arrangement is authorized by the customer. ...

(Tax Window, No. 24, p. 8, ¶2184)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt A direct payment by a non-resident to Revenue Canada of a tax liability of a related Canadian corporation would entail the receipt of an amount by the Canadian corporation for purposes of s. 12(1)(x). ...

7 August 1992 T.I. 921752 (May 1993 Access Letter, p. 198, ¶C76-066)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Because the function of a journal entry is to record a transaction rather than to make it legally effective, the reclassification of a shareholder's loan into remuneration payable by a journal entry would not be considered to be payment of the remuneration. ...

10 October 2014 APFF Roundtable Q. 6, 2014-0538251C6 F- 2014 APFF Roundtable, Q. 6- Application of subsection 75(2) after Sommerer-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission no comment on Pallen Trust CRA declined to comment on Pallen Trust, 2014 BCSC 305, as it had been appealed to the British Columbia Court of Appeal. ...

18 February 1999 External T.I. 9825635- VALIDITY OF 104(5.3) ELECTION-- summary under Rectification & Rescission Summary Under Tax Topics- General Concepts- Rectification & Rescission The comments in IT-378R, that the validity of an election may not be denied by a taxpayer once it is accepted by the Department, is applicable to other elections. ...

5 July 1990 TI AC59710-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt Where a promissory note is given in consideration for services, the acceptance of the note would be considered to be an amount received under s. 12(1)(a) where the note has been accepted as absolute payment for the services, whereas if the note has been accepted as conditional payment, s. 12(1)(a) will apply only when actual payments are made on the note assuming the related services have not yet been performed at that time. ...

13 June 2012 External T.I. 2012-0435351E5 F-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt issuance of cheque not payment Cheques issued by Opco but not yet cashed would not reduce its cash on hand given that under the applicable law (the Quebec Civil Code), the issuance of a cheque does not constitute payment, so that the debt is not settled until the cheque is honoured. ...