Words and Phrases - "advance"

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22 October 2001 External T.I. 2001-0070715 F - ALLOCATIONS AUTOMOBILES

car allowance was not a non-taxable advance because it was not required to be repaid if it exceeded the business kilometres

An employer was required to withhold pursuant to s. 153(1) on fixed automobile allowance paid monthly even though, at the end of the year, it...

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Words and Phrases
advance

15 April 2003 Internal T.I. 2002-0176687 F - IMPOT DES GRANDES SOCIETES AVANCES

Customers of the corporation paid for services in advance, which the corporation showed as a liability on its balance sheet but deducted as a...

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Words and Phrases
advance
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(c) prepaid revenues deducted under s. 20(6) were not a reserve 185

11 May 2005 Roundtable, 2005-0118731C6 F - Contrat avec une société d'affacturage

characterization as “loans and advances” and “all other indebtedness” based on legal character

A factoring company advances sums to Corporation A at a discount to the face value of the discounted receivables, and then applies the amounts...

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Words and Phrases
loan advance indebtedness

21 September 2007 External T.I. 2007-0229191E5 F - Agent de voyages & impôt de la partie I.3

customer advances received by travel agents and reported as deferred revenue in their balance sheets were “advances”

Quebec and Ontario travel agents were required by provincial legislation to hold funds collected from clients for services to be rendered to them...

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Words and Phrases
advance
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 181 - Subsection 181(3) - Paragraph 181(3)(b) - Subparagraph 181(3)(b)(i) customer advances received by travel agents and reported as deferred revenue in their balance sheets were required to be included in taxable capital even though amounts held in trust 109

26 April 2016 Internal T.I. 2015-0623571I7 - one-time salary transition payment

advance to employee is current s. 5 income

An employer is considering changing its payroll system to a payment-in-arrears system, so that employees will be paid for work that was done two...

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Words and Phrases
advance
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) deduction for repayment of transitional advance 163
Tax Topics - Income Tax Act - Section 80.4 - Subsection 80.4(1) employee advance not a “loan” 123

13 January 2012 Internal T.I. 2011-0414111I7 F - Deemed Interest Incomes - Exception 17(8)

CFA 1's purchased debt of CFA 2 did not qualify as a loan or advance

Where a taxable Canadian corporation makes a non-interest bearing loan to a controlled foreign affiliate (CFA 1) which, in turn, uses the proceeds...

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Words and Phrases
loan advance

TransCanada Pipelines Ltd. v. Minister of Revenue (1992), 62 O.A.C. 105

The respondent (a pipeline company) agreed to purchase certain minimum quantities of gas each year. If it was unable to take delivery of the...

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Words and Phrases
advance

Oerlikon Aérospatiale Inc. v. R., 99 DTC 5318, [1999] 4 CTC 358 (FCA)

The taxpayer financed its work on the manufacture of defence products under two contracts by receiving advances from the prime contractor or an...

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Words and Phrases
advance

Federated Cooperatives Ltd. v. The Queen, 2001 FCA 217, 2001 DTC 5414

bankers acceptances were not advances or bonds, debentures, notes, mortgages or similar obligations

Bankers acceptances held by the taxpayer were not "advances" to the issuer because the issuer had no obligation to repay the same sum of money to...

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