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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. ...

19 November 2012 External T.I. 2012-0459351E5- Shale Gas Well Drilling Classification-- summary under Scientific Research & Experimental Development Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Scientific Research & Experimental Development In considering the conditions under which a shale gas well would qualify for Canadian development expense credits, CRA noted that drilling the well may qualify for scientific research and experimental development credits if done for "experimental development of a new technology. ...

25 March 2009 External T.I. 2008-0300401E5 F- Fiducie en faveur de soi-même- prêt sans intérêt-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt individual pays trust taxes when he receives trust distributions net of such taxes CRA indicated that an individual would be considered to be personally paying taxes of a trust that had made a s. 104(13.1) where he received distributions from the trust net of such taxes. ...

29 April 2003 External T.I. 2002-0177065 F- CONFISCATION DE LA SOLDE-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt forfeited salary nonetheless includible as salary received CCRA indicated that salary that was forfeited by RCMP officer for misconduct nonetheless was to be treated as includible in the officer’s income as salary which was to be treated as having been received by the individual before its forfeiture as a fine. ...

11 October 2017 External T.I. 2016-0660421E5- Foreign tax credit – former resident-- summary under Subparagraph 152(4)(b)(i) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(4)- Paragraph 152(4)(b)- Subparagraph 152(4)(b)(i) waivers generally cannot be used to extend the 6-year period for claiming a FTC under s. 126(2.21) The taxpayer, who had been resident in Canada for over five years, realized a capital gain from the deemed disposition of real property situated outside Canada under s. 128.1(4)(b) on emigrating from Canada. ... After noting that “an assessment to take into account a foreign tax credit under subsection 126(2.21) … in respect of foreign taxes paid is permitted only where the assessment is made within 3 years after the normal reassessment period,” CRA stated: [A] blanket waiver request without sufficient details of a transaction would likely not be considered valid. …[I]f any of the circumstances to support the deduction under subsection 126(2.21) of the Act (e.g., disposition of the property and/or foreign taxes paid) are present within the statutory assessment period referred to in paragraph 152(4)(b) …, it may be appropriate for the Minister to consider a taxpayer’s waiver request for the emigration year to allow the Minister sufficient time to review and process any potential reassessment for this deduction beyond the aforementioned reassessment period. ...

6 November 2003 External T.I. 2003-0039525 F- Canadian Renewable & Conservation Expenses-- summary under Subparagraph (d)(viii) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 43.1- Paragraph (d)- Subparagraph (d)(viii) computers used in operating landfill biogas site might be Class 10 property, and applications software would be Class 43.1 or Class 12 property/ below-surface pipes would not qualify A corporation implementing a Canadian renewable and conservation expenses (CRCE) project that uses landfill sites, and injects them with bacteria to produce recoverable gas, puts a structure (pipes) into the ground to recover the gas. ... (d)(viii) of Class 43.1 then referred only to above-ground equipment, CCRA stated: Expenses of a capital nature incurred in respect of property that is not surface equipment (e.g., equipment buried in the ground) would not be covered by subparagraph (d)(viii) …. ... CCRA responded: [S]ubparagraph (d)(viii) of Class 43.1 … specifically excludes property otherwise included in Class 10. ...

26 November 1992 T.I. 923506 (September 1993 Access Letter, p. 411, ¶C20-1161)-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt For farmers on the cash method, a post-dated cheque that is received on a date that a debt owing to the taxpayer is not yet payable will be brought into income on the earlier of the date the debt becomes payable and the date the cheque is negotiated. ...

11 December 2013 External T.I. 2013-0474161E5- T-slips and dividend and interest-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt constructive receipt Respecting a question as to when dividends are paid and received for T5 purposes, CRA stated: In Innovative Installation Inc. v The Queen, 2009 TCC 580, the Tax Court of Canada explained that "received" does not require "proceeds to pass directly to the taxpayer. ...

6 November 2012 External T.I. 2012-0452531E5- Satisfactory Evidence of Payment-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note accepted as payment In response to a question as to whether "a demand note payable, which is accepted as absolute payment of salary owing to an employee, constitutes satisfactory evidence of the payment of that salary," CRA stated: An ordinary promissory note is generally regarded as a promise to pay a debt at a later date, and not as payment of the debt on the date on which the note was issued. ...