10 April 2024 External T.I. 2021-0919231E5 - Foreign tax allocation to a partner -- attach -- Payment & Receipt payment by partnership of withholding tax treated as a distribution to its partners Read more about 10 April 2024 External T.I. 2021-0919231E5 - Foreign tax allocation to a partner -- attach -- Payment & Receipt
2023 Ruling 2023-0973911R3 - Loss Consolidation Ruling -- attach -- Payment & Receipt daylight loan circled 4 times Read more about 2023 Ruling 2023-0973911R3 - Loss Consolidation Ruling -- attach -- Payment & Receipt
PepsiCo, Inc v Commissioner of Taxation, [2024] FCAFC 86 -- attach -- Payment & Receipt there can be no payment by direction unless there is an antecedent obligation by the creditor to the third party Read more about PepsiCo, Inc v Commissioner of Taxation, [2024] FCAFC 86 -- attach -- Payment & Receipt
18 September 2001 External T.I. 2001-0095265 F - TAXE SUR LE CAPITAL -- attach -- Payment & Receipt in Quebec, a cheque is not payment until the debtor’s account is debited Read more about 18 September 2001 External T.I. 2001-0095265 F - TAXE SUR LE CAPITAL -- attach -- Payment & Receipt
2023 Ruling 2023-0964601R3 - Loss consolidation arrangement -- attach -- Payment & Receipt in-house re-circulating daylight loan used to fund a loss-shifting transaction Read more about 2023 Ruling 2023-0964601R3 - Loss consolidation arrangement -- attach -- Payment & Receipt
Sussex Group - Allan Sutton Realty Corp. v. The King, 2024 TCC 1 (Informal Procedure) -- attach -- Payment & Receipt salary paid into her husband’s bank account was constructively received by the employee Read more about Sussex Group - Allan Sutton Realty Corp. v. The King, 2024 TCC 1 (Informal Procedure) -- attach -- Payment & Receipt
24 May 2002 Internal T.I. 2002-0130667 F - REGIME PRESTATION EMPLOYES -- attach -- Payment & Receipt amounts “received” under EBP if unrestricted right to receive Read more about 24 May 2002 Internal T.I. 2002-0130667 F - REGIME PRESTATION EMPLOYES -- attach -- Payment & Receipt
25 June 2002 Internal T.I. 2002-0130177 F - DEBENTURE CONVERTIBLE -- attach -- Payment & Receipt Teleglobe applied to find that amount paid by corporation on conversion of convertible debentures was the shares’ stated capital Read more about 25 June 2002 Internal T.I. 2002-0130177 F - DEBENTURE CONVERTIBLE -- attach -- Payment & Receipt
4 October 2002 Internal T.I. 2001-010564A F - PENSION ALIMENTAIRE-ARRERAGES -- attach -- Payment & Receipt set-off does not constitute payment unless the parties so agree Read more about 4 October 2002 Internal T.I. 2001-010564A F - PENSION ALIMENTAIRE-ARRERAGES -- attach -- Payment & Receipt
29 April 2003 External T.I. 2002-0177065 F - CONFISCATION DE LA SOLDE -- attach -- Payment & Receipt forfeited salary nonetheless includible as salary received Read more about 29 April 2003 External T.I. 2002-0177065 F - CONFISCATION DE LA SOLDE -- attach -- Payment & Receipt