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2 April 2019 Internal T.I. 2016-0649821I7 F- Unclaimed superannuation or pension benefits-- summary under Payment & Receipt Summary Under Tax Topics- General Concepts- Payment & Receipt amount received in Year 2 in lieu of pension benefit includes source deductions in Year 1 Although CRA usually applies its constructive receipt concepts in the context of employment income recognition, it has applied that concept to pension income recognition under s. 56(1)(a)(i). ... Its reasoning was that the amount could not be considered to be “received” as a pension benefit in the year of payment by the RPP administrator to the Directorate because the right-holder had not yet been identified – whereas in the subsequent year of payment over by the Directorate to the right-holder, that right-holder is receiving that amount under s. 56(1)(a)(i) as being “in lieu of” a superannuation or pension benefit. ...

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," ...

-- 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. ...

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.” ...

6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property-- summary under Subsection 149(10) Summary Under Tax Topics- Income Tax Act- Section 149- Subsection 149(10) unpurchased goodwill is taken into account Before going on to indicate that internally generated goodwill is considered in determining whether shares of a foreign affiliate of a corporation resident in Canada qualify as "excluded property" of another foreign affiliate of the corporation, CRA noted that in 9319777 and in 2002-0126653 "this Directorate took the position that internally generated goodwill was property of the taxpayer immediately prior to the transition time such that it was deemed to be disposed of, and reacquired, by the taxpayer for an amount equal to its fair market value." See summary under s. 95(1) – excluded property. ...

6 March 2015 Internal T.I. 2014-0549761I7- Internally generated goodwill & excluded property-- summary under Small Business Corporation Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(1)- Small Business Corporation unpurchased goodwill is taken into account Before going on to indicate that internally generated goodwill is considered in determining whether shares of a foreign affiliate of a corporation resident in Canada qualify as "excluded property" of another foreign affiliate of the corporation, CRA stated: [T]he "all or substantially all" test will normally be satisfied if assets representing at least 90 percent of the fair market value of the assets of the corporation are used in an active business carried on by it. ... See summary under s. 95(1) – excluded property. ...

22 June 2016 Internal T.I. 2016-0632821I7 F- 93(2.01) & Capital Contribution-- summary under Subsection 248(5) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(5) ordinary meaning of “substituted” Canco contributed (for no share consideration) its shares of a non-resident Finco subsidiary (Luxco2 – which previously had paid exempt dividends to Canco) to another wholly-owned subsidiary (Luxco1). ...

16 January 2017 Internal T.I. 2016-0651411I7- Reassessment period – transfer pricing-- summary under Subparagraph 402(3)(a)(i) Summary Under Tax Topics- Income Tax Regulations- Regulation 402- Subsection 402(3)- Paragraph 402(3)(a)- Subparagraph 402(3)(a)(i) reallocation of gross revenue consequential on s. 247(2) assessment A s. 247(2) transfer-pricing adjustment (“TPA”) was reassessed by CRA within the three years after the normal reassessment period to increase the sales proceeds on a cross-border sale. ... The Directorate found that CRA was also authorized by s. 152(4)(b)(iii) to reassess so as to reallocate both the pre-TPA and additional TPA revenue among the provinces – apparently even though this might only affect relative provincial taxable income and not affect federal taxable income (given that the TPA reassessment had already occurred). ...

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). ...