24 May 2002 Internal T.I. 2002-0130667 F - REGIME PRESTATION EMPLOYES -- attach -- Payment & Receipt
amounts “received” under EBP if unrestricted right to receive
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
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
29 April 2003 External T.I. 2002-0177065 F - CONFISCATION DE LA SOLDE -- attach -- Payment & Receipt
forfeited salary nonetheless includible as salary received
7 November 2022 External T.I. 2022-0926091E5 - Transfer of UK DB pension benefits to a UK SIPP -- attach -- Payment & Receipt
constructive receipt doctrine applied to direct payment from one UK pension plan to UK individual pension plan
23 January 2023 External T.I. 2020-0865161E5 F - SSUC/CEWS – Sous-alinéa 125.7(4)e)(i) et personne -- attach -- Payment & Receipt
a cash-basis taxpayer can receive an amount when it is received through a third party
1 August 1996 External T.I. 9604555 - AMOUNT PAYABLE SUBSECTION 104(24) -- attach -- Payment & Receipt
promissory note normally only constitutes an enforceable right to the income where it is payable on demand
25 September 2003 Internal T.I. 2003-0032837 F - Market Maker: Reserve Account for Losses -- attach -- Payment & Receipt
constructive receipt by employee where reserve loss account (funded out of commissions) is transferred from old brokerage employer to new brokerage employer
2021 Ruling 2021-0911211R3 - Foreign Takeover -- attach -- Payment & Receipt
borrowing and payment of funds pursuant to an internal payment direction agreement
Ristorante a Mano Limited v. Canada (National Revenue), 2022 FCA 151 -- attach -- Payment & Receipt
net tips on restaurant credit card sales distributed to the servers were earnings "paid" to them
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