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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. ...

17 June 2014 External T.I. 2013-0506731E5- Immigration-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt note satisfied dividend An individual shareholder immigrates to Canada, thereby becoming a Canadian resident. ...

16 March 2015 Internal T.I. 2013-0479861I7- Section 116 & forfeited deposits on real property-- summary under Paragraph (b) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Disposition- Paragraph (b) forfeited sale deposit was proceeds Before finding that a deposit forfeited to a non-resident vendor under an agreement for sale of B.C. real property (due to failure of the purchaser to close) did not represent proceeds of taxable Canadian property by virtue of s. 248(4), CRA first stated (based on the s. 248(1) – "disposition" definition) that "there is a disposition of a right under a contract where an agreement of sale has been cancelled and the buyer's deposit is forfeited to the vendor," ...

6 October 2017 APFF Financial Strategies and Instruments Roundtable Q. 16, 2017-0705181C6 F- Hedging & George Weston Limited-- summary under Futures/Forwards/Hedges Summary Under Tax Topics- Income Tax Act- Section 9- Capital Gain vs. Profit- Futures/Forwards/Hedges CRA is considering changing its policy re what is capital hedge After noting that “the CRA has already stated that it accepts the decision … in George Weston,” CRA noted, however, that: The approach taken by the TCC in [MacDonald] respecting, inter alia, the linkage principle appears to be irreconcilable with previous jurisprudence, including George Weston Limited.... ...

-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt receipt of cheque (that is not subsequently dishonoured) is payment at that time A payment by cheque is equivalent to a payment in cash as long as no special circumstances lead to another conclusion, and the cheque is not dishonoured on presentation for payment. ...

5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 10, 2018-0761551C6 F- Attribution rules and promissory note-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt promissory note could not be issued as payment in context of income attribution rules Where a loan is made to a spouse at the prescribed interest rate, s. 74.5(2) requires that each year’s interest be “paid” by January 30 of the following year. ...

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. ...