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The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt sending of cheque to sender's lawyers The sending of a cheque by the lender to (its) solicitors did not constitute the payment of a sum to the borrower. ...

The Queen, 2012 DTC 1106 [at at 3044], 2012 TCC 86-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt past services Margeson J. accepted (at para. 99) that employees to whom the taxpayer issued shares in payment of bonuses to them gave consideration equal to the full value of those share "on the basis of past unremunerated services rendered to the Appellant. ...

Ans, 83 DTC 5038, [1983] CTC 8 (FCTD)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt by set-off A company's shareholder was held to have received a bonus when the amount of the bonus payable by the company was credited against the balance outstanding on the loan by the company to the shareholder. ...

The Queen, 2010 DTC 1213 [at at 3568], 2010 TCC 321 (Informal Procedure)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt frequent flyer points Frequent flyer points applied by the taxpayer to purchase air tickets to Chicago for medical treatment there constituted "an amount paid" for purposes of s. 118.2(2)(g). ...

Smith, [1985] BTC 25 (HC)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt only when cheque deposited Interest paid by cheque was not received on the date that the cheque was received. ...

., 99 DTC 537, [1999] 3 CTC 2123 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development Two projects for the development of a system for recycling sludge or dealing more economically with the disposition of waste chemicals did not evidence a type of uncertainty that could not be removed by standard engineering practice and routine development and, accordingly, did not qualify. ...

The Queen, 2000 DTC 2353 (TCC)-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development McArthur TCJ found (at p. 2360): "What the Appellant did was take existing technology computer hardware and PacRat software, and record personal messages that cannot be understood or tested by anyone else but [its principal]. ...

The Queen, 97 DTC 684, [1997] 1 CTC 2256 (TCC)-- 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 found not to be engaged in SR&ED given that the only tests conducted by it in the year in question was testing of devices already on the market that had been designed from technologies developed in the United States. ...

.)-- 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. ...