Payment & Receipt

Table of Contents

Payment & Receipt
Cases(21)
See Also(31)
Administrative Policy(40)
Articles(6)

Cases

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

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Words and Phrases
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 (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) 120

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) 74

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) 81

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 194

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) 65

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 700
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 270

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 (TCC)

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Phillips v. The Queen, 95 DTC 194 (TCC)

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Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) 97

Blais v. MNR, 92 DTC 1497 (TCC)

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Ed Sinclair Construction & Supplies Ltd. v. MNR, 92 DTC 1163 (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 204

Administrative Policy

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

S3-F6-C1 - Interest Deductibility

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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

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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Tax Topics - Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) 76

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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IT-196R2 "Payments by Employer to Employee"

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

Articles

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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