Kufsky v. Canada, 2022 FCA 66 -- attach -- Payment & Receipt
dividend was paid by way of retroactive set-off against shareholder loan account
Payment & Receipt
15 March 2019 External T.I. 2018-0766021E5 - Obligation to prepare T4A slips -- attach -- Payment & Receipt
the payer is the person who has discretion and control over the funds
2021 Ruling 2021-0876671R3 - Transfer between US pension plans -- attach -- Payment & Receipt
no constructive receipt to Canadian beneficiaries where the transfer of a portion of the assets and Canadian beneficiaries from an old to a new US pension plan
9 May 2006 Internal T.I. 2006-0176371I7 F - Bourses d'études ou d'entretien -- attach -- Payment & Receipt
bursaries “received” by students even though required to be applied directly to their loans
14 June 2007 Internal T.I. 2007-0229311I7 F - Capital Dividend Account -- attach -- Payment & Receipt
making accounting entries does not constitute payment of a dividend
29 March 2021 Internal T.I. 2020-0865791I7 - CEWS - eligible remuneration -- attach -- Payment & Receipt
remuneration not considered to be paid by journal entry
21 April 2008 Internal T.I. 2007-0251761I7 F - Billet à payer -- attach -- Payment & Receipt
addition of unpaid interest to principal was not a loan of money, nor a payment or crediting of interest
29 September 2020 External T.I. 2018-0757501E5 F - Crédit pour intérêts sur les prêts étudiants -- attach -- Payment & Receipt
capitalization of interest on a novation under Quebec law would constitute its payment
25 March 2009 External T.I. 2008-0300401E5 F - Fiducie en faveur de soi-même - prêt sans intérêt -- attach -- Payment & Receipt
individual pays trust taxes when he receives trust distributions net of such taxes
Moody v. MNR, 57 DTC 1050, [1957] CTC 110 (Ex Ct) -- attach -- Payment & Receipt
cheque generally payment when received
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