Section 78

Subsection 78(1) - Unpaid amounts

Cases

Canada v. Dow Chemical Canada Inc., 2008 DTC 6544, 2008 FCA 231

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 87 - Subsection 87(7) 193

Minister of National Revenue v. Shofar Investment Corporation, 79 DTC 5347, [1979] CTC 433, [1980] 1 S.C.R. 350

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See Also

Dow Chemical Canada Inc. v. The Queen, 2007 DTC 1701, 2007 TCC 668

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Redclay Holdings Ltd. v. The Queen, 96 DTC 1207 (TCC)

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) interest not payable if contingent cash flow 192

Administrative Policy

30 August 1995 T.I. 952011 (C.T.O. "Application of 78(1) and 18(4)")

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(4) 36

IT-109R2 "Unpaid Amounts" 23 April 1993

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27 March 1992 External T.I. 5-920554 -

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17 January 1992 T.I. (Tax Window, No. 15, p. 11, ¶1704)

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91 CPTJ - Q.31

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17 September 1991 T.I. (Tax Window, No. 9, p. 3, ¶1453)

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28 May 1991 T.I. (Tax Window, No. 3, p. 29, ¶1267)

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90 C.P.T.J. - Q.37

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2 May 1990 T.I. (October 1990 Access Letter, ¶1467)

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11 April 1990 T.I. (September 1990 Access Letter, ¶1422)

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89 C.P.T.J. - Q26

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88 C.R. - Q.3

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81 C.R. - Q.11

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Articles

Brahmst, "Non-Arm's Length Expenses and Section 78", Practice Notes, Canadian Current Tax, April 1991, p. P33

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Paragraph 78(1)(b)

Subparagraph 78(1)(b)(ii)

Administrative Policy

15 May 2019 IFA Roundtable Q. 4, 2019-0798721C6 - 78(1)(b)(ii) deemed loan & thin capitalization

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(5) - Outstanding Debts to Specified Non-Residents - Paragraph (a) - Subparagraph (a)(ii) unpaid simple interest that is deemed to be a loan by s. 78(1)(b)(ii) generally is not outstanding debts to specified non-residents 160

Subsection 78(4) - Unpaid remuneration and other amounts

See Also

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

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt payment by demand loan 62

Administrative Policy

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

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt promissory note accepted as payment 98

2 October 2012 External T.I. 2012-0446671E5 F - Subsection 78(4)

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7 August 1992 T.I. 921752 (May 1993 Access Letter, p. 198, ¶C76-066, (Tax Window, No. 23, p. 5, ¶2140)

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87 C.R. - Q.19

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87 C.R. - Q.32

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