Words and Phrases - "appropriate advance"

a
87
b
44
c
77
d
51
e
38
f
31
g
18
h
14
i
74
j
2
k
2
l
32
m
56
n
25
o
38
p
80
q
3
r
76
s
90
t
46
u
16
v
9
w
23
y
2

ADP Canada Co.(Canadian Automatic Data Processing Services Ltd.) v. Canada, 2009 DTC 5091, 2009 FCA 117

Summary Under
Tax Topics - Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(c)

The taxpayer, which provided payroll services for a fee, received funds from its clients in advance of the required remittance of such funds by it on their behalf. The funds received:

"were not 'advances' to ADP because they were neither a payment made to ADP before it was due nor an amount to be applied against the price of the service, paid before the service is rendered, nor an amount paid to ADP for an expenditure of ADP."

Words and Phrases
appropriate advance