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17 February 2004 External T.I. 2003-0033915- Cash pooling- shareholder benefit-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt no automatic set-off In indicating that a cash pooling arrangement entered into by a Canadian subsidiary with its non-resident parent corporation could result in an income inclusion under s. 15(2), Revenue Canada indicated that its review of the jurisprudence on s. 15(2) suggested that debts between a shareholder and a particular corporation do not generally offset for purposes of determining either whether the shareholder became indebted to the corporation in the first place, or whether that indebtedness has been repaid. ...

14 May 2019 CLHIA Roundtable Q. 3, 2019-0799111C6- 2019 CLHIA Q3- 3rd party RRSP contributions-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment at direction of annuitant is payment by annuitant CRA indicated that it is acceptable for an RRSP contribution to be received from a third party (i.e., drawn on a bank account other than the annuitant’s) “provided that the payment is made at the direction or with the concurrence of the annuitant of the RRSP,” so that the RRSP receipt should be issued by the financial institution to the annuitant. ...

29 March 2021 Internal T.I. 2020-0865791I7- CEWS- eligible remuneration-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt remuneration not considered to be paid by journal entry The CEWS (wage subsidy) is generated based on the amounts of “eligible remuneration paid to the eligible employee.” ...

2023 Ruling 2023-0973911R3- Loss Consolidation Ruling-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt daylight loan circled 4 times CRA ruled on a triangular loss-shifting transaction between Lossco and its subsidiary, Profitco, under which Lossco used a daylight loan to make an interest-bearing loan (pursuant to the “IB Note”) to Profitco, who subscribed for preferred shares of its sister, “Numberco,” who made a non-interest-bearing loan to Lossco. ...

10 April 2024 External T.I. 2021-0919231E5- Foreign tax allocation to a partner-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt payment by partnership of withholding tax treated as a distribution to its partners Regarding the allocation of foreign tax by a partnership to a partner, CRA stated: If the partnership pays the foreign tax on behalf of the partner or the foreign tax is withheld on behalf of the partner in accordance with foreign law from the foreign income paid to the partnership, such amount would be considered [for purposes of s. 53(2)(c)(v)] to be received by the partner on account or in lieu of payment of, or in satisfaction of, a distribution of the partner’s share of the partnership profits or partnership capital. ...

13 June 2012 Internal T.I. 2012-0435351I7 F- SEPE- chèques en circulation-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in Quebec, payment by cheque does not occur until debiting of bank account Are the cash assets of Opco reduced by the amount of issued and outstanding cheques that have not yet been cashed? CRA responded: Under the civil law in force in Quebec, the delivery of an outstanding cheque does not constitute payment … [and] the date of payment of a debt settled by cheque is considered to be the date on which the cheque is honoured or paid by the bank …. [Here] the cheques in circulation and not yet cashed do not constitute payments of the amounts due to Opco's suppliers and … consequently, there can be no reduction in the amount of the cash of Opco as long as the bank does not honour or pay such cheques. ...

18 September 2001 External T.I. 2001-0095265 F- TAXE SUR LE CAPITAL-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt in Quebec, a cheque is not payment until the debtor’s account is debited In indicating that outstanding cheques of a corporation do not represent loans or advances, CCRA stated: The delivery of a cheque (other than a certified cheque, money order or any other equivalent instrument) by a corporation governed by the Civil Code does not constitute a payment since, according to Article 1564 of the Civil Code, the payment transaction cannot be completed until the debtor's bank has actually paid the amount. … Consequently, the payment date is considered to be the date on which the cheque is honoured or discharged by the bank, which normally occurs … on the date on which the cheque in question is debited from the debtor's account. ...

7 December 2010 External T.I. 2010-0363431E5 F- Date limite cotisation REER-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt RRSP premium “paid” when cheque received by issuer, not when it’s deposited In commenting on whether an RRSP premium is considered to have been paid within the first 60 days of a year, CRA stated: In general, we consider a premium to have been paid on or before the 60th day after the end of the calendar year if the RRSP issuer received a cheque for an RRSP contribution on or before the 60th day, and the date of the cheque is also on or before the 60th day. ...

21 July 2009 Internal T.I. 2009-0322591I7 F- Déduction des intérêts-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt replacement of note with capitalized note with note for full amount did not constitute payment by novation The taxpayer purchased assets from the vendor (apparently, a non-resident) in consideration for shares of the taxpayer and interest-bearing debt, that was evidenced by a note providing that unpaid interest could be added to the principal of the note. ...

9 May 2006 Internal T.I. 2006-0176371I7 F- Bourses d'études ou d'entretien-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt bursaries “received” by students even though required to be applied directly to their loans CRA found that bursaries paid to Quebec students under the Program québécois de prêts et bourses (the Quebec loans and bursaries program) by converting loans initially made to them into bursaries (following an ARQ verification of their income) that, thus, did not have to be repaid, were includible in income under s. 56(1)(n), subject to the exclusions under s. 56(3). ...