Payment & Receipt

Cases

Canada v. Innovative Installation Inc., 2010 DTC 5175 [at 7317], 2010 FCA 285

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receive
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Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account receipt of insurance proceeds through debt repayment 156

Wannan v. Canada, 2003 DTC 5715, 2003 FCA 423

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Banner Pharmacaps NRO Ltd. v. Canada, 2003 FCA 367, 2003 DTC 5642 (FCA)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(j) dividends recognized on cash basis 117
Tax Topics - Income Tax Act - Section 133 - Subsection 133(8) - Non-Resident-Owned Investment Corporation dividend received when note issued/such note not a money-lenidng business 227

Canada v. Gillette Canada Inc., 2003 DTC 5078, 2003 FCA 22

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Hickman Motors Ltd. v. Canada, 97 DTC 5363, [1997] 2 S.C.R. 336

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Piché v. MNR, 93 DTC 5295 (FCA)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) interest received upon the receipt of cheque 100

Coppley Noyes & Randall Ltd. v. The Queen, 91 DTC 5291 (FCTD), varied on appeal 93 DTC 5196, 5508 (FCA).

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Minsham Properties Ltd. v. Price, [1990] BTC 528 (Ch. D.)

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Cumberland Properties Ltd. v. The Queen, 89 DTC 5333, [1989] 2 CTC 75 (FCA)

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C. & E. Commissioners v. Faith Construction Ltd., [1989] BTC 5121 (C.A.)

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Tax Topics - Excise Tax Act - Section 341 - Subsection 341(1) 124

Parkside Leasing Ltd. v. Smith, [1985] BTC 25 (HC)

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Narich Pty. Ltd. v. Commissioner of Pay-roll Tax, [1984] BTC 8019 (PC)

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 76

Western Union Insurance Co. v. The Queen, 83 DTC 5388, [1983] CTC 363 (FCTD)

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The Queen v. Ans, 83 DTC 5038, [1983] CTC 8 (FCTD)

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Mendels v. The Queen, 78 DTC 6267, [1978] CTC 404 (FCTD)

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The Queen v. Canadian-American Loan and Investment Corp. Ltd., 74 DTC 6104, [1974] CTC 101 (FCTD)

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) 83

Blauer v. MNR, 71 DTC 5113, [1971] CTC 154 (F.C.T.A.), briefly aff'd 75 DTC 5076, [1975] CTC 112 (SCC)

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Hall v. MNR, 70 DTC 6333, [1970] CTC 510 (Ex Ct), briefly aff'd 71 DTC 5217 (SCC)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) sale of matured interest coupons gave rise to interest receipt or amount in lieu 204

Robwaral Ltd. v. MNR, 60 DTC 1025, [1960] CTC 16 (Ex Ct), briefly aff'd 64 DTC 5266 (SCC)

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(1) 67

Moody v. MNR, 57 DTC 1050 (Ex Ct)

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Flinn v. MNR, 3 DTC 1157, [1948] Ex. C.R. 272 (Ex Ct)

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See Also

Clark v HM Revenue and Customs, [2020] EWCA Civ 204

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Black v. The Queen, 2019 TCC 135

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) an ancillary income-earning purpose for making a loan whose terms were never finalized was sufficient to satisfy s. 20(1)(c)(i) 659
Tax Topics - General Concepts - Effective Date loan was effective even though never documented and ultimately repudiated 380

Borealis Geopower Inc. v. The Queen, 2018 TCC 189 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 37 - Subsection 37(1) - Paragraph 37(1)(d) taxpayer had “physically” received unearned government assistance because it had authority to deal with the funds 243
Tax Topics - Income Tax Act - Section 162 - Subsection 162(11) loss carryback did not reduce late-filing penalty or interest 278

Blott v. The Queen, 2018 TCC 1 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(i) - Subparagraph 8(1)(i)(ii) retaining an assistant was not a requirement of employer 121

Markou v. The Queen, 2016 TCC 137

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Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(1) TCC had jurisdiction to determine that no lender equitable remedy (under Quistclose trust doctrine) attached to leveraged donation advances 425
Tax Topics - Statutory Interpretation - Interpretation Act - Section 8.1 TCC has jurisdiction to determine existence of equitable remedy 96

M. Soutar Decor 2000 Ltd. v. The Queen, 2016 TCC 62 (Informal Procedure)

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Tax Topics - Income Tax Act - Section 160 - Subsection 160(1) transfer from guarantor by virtue of seizure of security by tax debtor’s bank 308

Blank v. Commissioner of Taxation, [2015] FCAFC 154, aff'd [2016] HCA 42

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) phantom profit participation unit amounts not income until paid by employer rather than when due 737
Tax Topics - Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) no apportionment possible between resident and non-resident services 286

Great-West Life Assurance Company v. The Queen, 2015 TCC 225

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Tax Topics - Excise Tax Act - Regulations - Financial Services (GST/HST) Regulations - Subsection 4(2) electronic drug plan adjudication and processing was "quintessentially administrative in nature" 279
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (f.1) essential character of drug claim processing service was providing payment to the claimant 306
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.4) services described in (r.4) did not represent the essential character of drug claim processing service 269
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (r.5) essential character of drug claim processing service was providing payment to the claimant 186

Dimane Enterprises Ltd. v. The Queen, 2015 DTC 1013 [at 64], 2014 TCC 334

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Tax Topics - General Concepts - Sham purported recipients of trust distributions had no control over funds 242
Tax Topics - Income Tax Act - Section 144 - Subsection 144(1) - Employee Profit Sharing Plan purported recipients of trust distributions had no control over funds 242

Transalta Corporation v. The Queen, 2012 DTC 1106 [at 3044], 2012 TCC 86

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McKenzie v. The Queen, 2011 DTC 1216 [at 1274], 2011 TCC 289

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Words and Phrases
distributed

Newmont Canada Corporation v. The Queen, 2011 DTC 1117 [at 628], 2011 TCC 148, aff'd 2012 DTC 5138 [at 7292], 2012 FCA 214 supra

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Words and Phrases
reimbursement

Sochatsky v. The Queen, 2011 DTC 1065 [at 346], 2011 TCC 41, 2012 TCC 65

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) amount booked as loaned-back bonus was remuneration 186
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) 168

Merchant v. The Queen, 2010 TCC 467

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Johnson v. The Queen, 2010 DTC 1213 [at 3568], 2010 TCC 321 (Informal Procedure)

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Innovative Installation Inc. v. The Queen, 2009 DTC 1388 [at 2135], 2009 TCC 580, aff'd supra

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O'Dea v. The Queen, 2009 DTC 912, 2009 TCC 295

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Collins & Aikman Products Co. v. The Queen, 2009 DTC 1179 [at 958], 2009 TCC 299, aff'd 2010 DTC 5164 [at 7293], 2010 FCA 251

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WPH Mechanical Services Ltd. v. The Queen, 2007 DTC 263, 2006 TCC 677

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Aprile v. The Queen, 2005 DTC 585, 2005 TCC 216 (Informal Procedure)

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Hill v. The Queen, 2002 DTC 1749 (TCC)

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) 213
Tax Topics - Income Tax Act - Section 245 - Subsection 245(4) no Crown explanation of different treatment of simple interest 241

MacNiven v. Westmoreland Investments Ltd., [2001] 1 All ER 865 (HL)

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Fleishman v. The Queen, 98 DTC 1836 (TCC) (Informal Procedure)

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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) payment applied by creditor to principal 70

Gibson v. The Queen, 95 DTC 749, [1996] 1 CTC 2105 (TCC) (Informal Procedure)

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Phillips v. The Queen, 95 DTC 194, [1994] 2 CTC 2416 (TCC)

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 103

Blais v. MNR, 92 DTC 1497 (TCC)

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Ed Sinclair Construction & Supplies Ltd. v. MNR, 92 DTC 1163, [1992] 1 CTC 2218 (TCC)

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Re Charge Card Services Ltd., [1988] 3 All E.R. 702 (C.A.)

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Associated Insulation Products, Ltd. v. Golder (1944), 26 TC 231, [1944] 2 All E.R. 203 (C.A.)

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Cross v. London Provincial Trust Ltd., [1938] 1 All E.R. 428 (C.A.)

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Gresham Life Society Co., Ltd. v. Bishop (1902), 4 TC 464 (HL)

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Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) no constructive receipt 210

Administrative Policy

29 March 2021 Internal T.I. 2020-0865791I7 - CEWS - eligible remuneration

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Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(2) remuneration not paid by journal entry 164
Tax Topics - Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Remuneration - Paragraph (c) eligible remuneration that is returned to the eligible employer as a capital contribution or shareholder loan adjustment is excluded for CEWS purposes 187

29 September 2020 External T.I. 2018-0757501E5 F - Crédit pour intérêts sur les prêts étudiants

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Tax Topics - Income Tax Act - Section 118.62 capitalization of interest on a novation would constitute its payment – but novated loan would be a new non-student loan 221
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(d) capitalization of unpaid interest by way of novation constituted its payment 66

13 August 2020 External T.I. 2019-0802891E5 F - Unclaimed RRSP Benefits

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(1) - Benefit - Paragraph (a) benefit includible in deceased annuitant’s return was not subject to "benefit"-(a) exclusion because it was not reported 312
Tax Topics - Income Tax Act - Section 146 - Subsection 146(8) s. 146(8) benefit paid to the taxpayer’s administrator was not includible in her income until the year she was identified and received the amount 369
Tax Topics - Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(c) tax imposed on RRSP under s. 146(4)(c) where RRSP issuer unaware of annuitant’s death 187
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose fees incurred as a consequence of receiving unclaimed property (which was taxable under s. 146(8)) were non-deductible 205
Tax Topics - Income Tax Act - Section 9 - Timing receipt of income by an administrator was not income of the beneficial owner until the year she was identified 350

14 May 2019 CLHIA Roundtable Q. 3, 2019-0799111C6 - 2019 CLHIA Q3 - 3rd party RRSP contributions

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(5) a 3rd party can make an RRSP contribution 162

2 April 2019 Internal T.I. 2016-0649821I7 F - Unclaimed superannuation or pension benefits

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Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) subsequent year’s payment of benefit to a previously-unidentified beneficiary is only income in that year as an “in lieu of” pension amount 628

5 October 2018 APFF Financial Strategies and Instruments Roundtable Q. 10, 2018-0761551C6 F - Attribution rules and promissory note

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Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(2) - Paragraph 74.5(2)(b) accrued interest cannot be “paid” for s. 74.7 purposes by issuing a promissory note 242

17 June 2014 External T.I. 2013-0506731E5 - Immigration

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Tax Topics - Income Tax Act - Section 128.1 - Subsection 128.1(1) dividend receivable acquired on immigration 141
Tax Topics - Income Tax Act - Section 90 - Subsection 90(2) dividend not recognized until paid 180

24 November 2013 CTF Roundtable, 2013-0508151C6 - Upstream Loans

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Tax Topics - Income Tax Act - Section 90 - Subsection 90(8) - Paragraph 90(8)(a) repayment by set-off 75

30 January 2014 External T.I. 2013-0515761E5 F - Dividend received

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Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) book entries are ancillary and do not establish receipt 175

11 December 2013 External T.I. 2013-0474161E5 - T-slips and dividend and interest

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Tax Topics - Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) constructive receipt 98

7 October 2013 Internal T.I. 2013-0504081I7 F - Interaction between 55(2) and 40(1)(a)(iii)

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Tax Topics - Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) reserve available for s. 55(2) gain on purchase for cancellation of shares where redemption proceeds payable on an earnout basis 268
Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) s. 40(1)(a)(iii) reserve available where redemption proceeds payable on earnout basis 173

6 November 2012 External T.I. 2012-0452531E5 - Satisfactory Evidence of Payment

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13 June 2012 Internal T.I. 2012-0435351I7 F - SEPE - chèques en circulation

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation outstanding and uncashed cheques did not reduce cash 145

4 July 2011 External T.I. 2011-0401991E5 F - CDA and life insurance proceeds

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13 June 2012 External T.I. 2012-0435351E5 F -

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation cheques not yet cashed 48

30 March 2011 External T.I. 2010-0390591E5 F - Cotisation spéciale

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Tax Topics - Income Tax Act - Section 9 - Timing amounts assessed against the taxpayer by co-owners not deductible until expended on or in the business 219
Tax Topics - Income Tax Act - Section 248 - Subsection 248(16) - Paragraph 248(16)(a) - Subparagraph 248(16)(a)(i) addition for GST and subtraction for ITC 141

7 December 2010 External T.I. 2010-0363431E5 F - Date limite cotisation REER

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Tax Topics - Income Tax Act - Section 146 - Subsection 146(5) 60-day contribution deadline is met based on receipt of cheque by issuer, not its deposit 122

21 July 2009 Internal T.I. 2009-0322591I7 F - Déduction des intérêts

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Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Disposition replacement of note and capitalized interest by new note with increased amount did not constitute payment by novation of the old debt 193
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) issuance of replacement promissory note for amount of previous principal plus capitalized interest was not a crediting of such interest 151

25 March 2009 External T.I. 2008-0300401E5 F - Fiducie en faveur de soi-même - prêt sans intérêt

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Tax Topics - Income Tax Act - Section 75 - Subsection 75(2) Howson applied to find that non-interest bearing loan by individual to his alter ego trust not subject to s. 75(2)/no contribution if individual pays trust taxes following a s. 104(13.1) election 181
Tax Topics - Income Tax Act - 101-110 - Section 104 - Subsection 104(13.1) s. 104(13.1) election generally available where no s. 75(2) application, which is not engaged by the individual’s payment of trust-level taxes 357
Tax Topics - Income Tax Act - Section 56 - Subsection 56(4.1) s. 56(4.1) inapplicable to NIB loan made by individual to his alter ego trust 139

21 April 2008 Internal T.I. 2007-0251761I7 F - Billet à payer

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Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(d) addition of unpaid interest to principal did not establish a loan of that interest or a novation of the debt – so that interest on such capitalized interest non-deductible until paid 243
Tax Topics - Income Tax Act - Section 212 - Subsection 212(1) addition of unpaid interest to principal was not a payment or crediting of the interest so as to engage Pt. XIII tax 109

14 June 2007 Internal T.I. 2007-0229311I7 F - Capital Dividend Account

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Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (b) recording of dividend payable and dividend receivable between sub and parent was insufficient to constitute the payment of a capital dividend, so that there was no CDA addition 132
Tax Topics - Income Tax Act - Section 184 - Subsection 184(3) invalid payment of capital dividend (because no payment) was subject to Pt. III tax (given valid s. 83(2) election) for which no s. 184(3) election could be made as no payment 135
Tax Topics - General Concepts - Effective Date a declared dividend cannot be revoked 158

17 February 2004 External T.I. 2003-0033915 - Cash pooling - shareholder benefit

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(2.6) cash pooling with NR parent 77

IT-243R4, para 5

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2 April 1998 Roundtable, E9722066 - PROMISSORY NOTE -WHETHER PAYMENT OF DEBT?

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Tax Topics - Income Tax Act - Section 28 - Subsection 28(1) - Paragraph 28(1)(a) promissory note accepted as absolute payment for the transfer of inventory given that no remedy provided for non-payment 145

5 January 1996 CTF Roundtable Q. 31, 9523976 - GROSS-UP PAYMENTS

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30 June 1995 Internal T.I. 9503907 - TAX STATUS OF CHEQUE RETURNED BY CASH METHOD FARMER?

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19 June 1995 Memorandum 950842 (C.T.O. "Patronage Dividends Paid by Non Co-ops")

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7 May 1995 Internal T.I. 9510220 - PART I.3, O/S CHEQUES & OVERDRAFTS

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6 July 1994 Internal T.I. 9323826 - BONDS ISSUED IN LIEU OF INTEREST

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1993 A.P.F.F. Round Table, Q.15

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26 November 1992 T.I. 923506 (September 1993 Access Letter, p. 411, ¶C20-1161)

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Tax Topics - Income Tax Act - Section 28 - Subsection 28(1) 59

31 August 1992 T.I. (Tax Window, No. 24, p. 8, ¶2184)

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7 August 1992 T.I. 921752 (May 1993 Access Letter, p. 198, ¶C76-066)

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28 July 1992 Memorandum 921859 (April 1993 Access Letter, p. 151, ¶C180-136)

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15 June 1992 T.I. 921368 (December 1992 Access Letter, p. 18, ¶C56-208)

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Tax Topics - Income Tax Act - Section 74.5 - Subsection 74.5(1) 38

3 July 1991 Memorandum (Tax Window, No. 5, p. 22, ¶1335)

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5 July 1990 TI AC59710

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85 C.R. - Q.29

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84 C.R. - Q.13

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IT-436R "Reserves - Where Promissory Notes are Included in Disposal Proceeds"

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IT-168R2, para. 3-4

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IT-305R3 "Establishment of Testamentary Spouse Trust"

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Tax Topics - Income Tax Act - Section 70 - Subsection 70(6) 0

IT-196R2 "Payments by Employer to Employee"

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(3) 0

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Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper

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Kevin Bianchini, Reuben Abitbol, "Taxation of Stock Appreciation Rights", Taxation of Executive Compensation and Retirement (Federated Press), Vol. 24 No. 8, 2015, p.1655

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E.G. McKendrick, Chitty on Contracts, Vol. 1, Thirtieth Edition (2008).

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C.R.B. Dunlop, Creditor-Debtor Law in Canada, Second Edition (1994).

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Arnold, "Timing and Income Taxation: The Principles of Income Measurement for Tax Purposes", Canadian Tax Paper, No. 71, Canadian Tax Foundation, July 1983

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Wilson, "Repayment of Shareholder Loans", 1995 Canadian Tax Journal, Vol. 43, No. 3, p. 746.

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