advance

Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(4) - Paragraph 181.2(4)(b)
balance of sale, although a debt, is not a “loan or advance”/ prepaid expenses are “advances”

The Agency indicated that “a balance of sale is a debt that does not have the character of a loan or advance within the meaning of paragraph...

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Words and Phrases
advance debt
Summary Under
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b)
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
Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(b)
prepaid revenues were an “advance”

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
Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(f)
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
Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(c)
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
Summary Under
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1)
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
Summary Under
Tax Topics - Income Tax Act - Section 17 - Subsection 17(8) - Paragraph 17(8)(a) - Subparagraph 17(8)(a)(ii)
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

Federated Cooperatives Ltd. v. The Queen, 2001 FCA 217, 2001 DTC 5414 -- summary under Subsection 181.2(4)

Full Title
Federated Cooperatives Ltd. v. The Queen, 2001 FCA 217, 2001 DTC 5414
Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(4)
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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Words and Phrases
bankers acceptance
advance
bond, debenture, note, mortgage or similar obligation

Oerlikon Aérospatiale Inc. v. R., 99 DTC 5318, [1999] 4 CTC 358 (FCA) -- summary under Subsection 181.2(3)

Full Title
Oerlikon Aérospatiale Inc. v. R., 99 DTC 5318, [1999] 4 CTC 358 (FCA)
Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3)

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

TransCanada Pipelines Ltd. v. Minister of Revenue (1992), 62 O.A.C. 105 -- summary under Subsection 181.2(4)

Full Title
TransCanada Pipelines Ltd. v. Minister of Revenue (1992), 62 O.A.C. 105
Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(4)

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
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