Words and Phrases - "receive"

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Sussex Group - Allan Sutton Realty Corp. v. The King, 2024 TCC 1 (Informal Procedure)

salary paid into her husband’s bank account was constructively received by the employee

The appellant, a real estate brokerage firm, determined (based on agreement between its two employees) that the remuneration paid to them would be...

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Words and Phrases
receive
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 227 - Subsection 227(9) penalty reversed because Crown could not prove the full amount of remuneration re-allocated by it between two employees 269
Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) salary paid into a spouse’s account but available to the taxpayer was constructively received by her 203
Tax Topics - General Concepts - Onus s. 227(9) penalty reversed because Crown could not meet the onus on it to establish the full amount on which it imposed it 233

Odette (Estate) v. The Queen, 2021 TCC 65

a promissory note subsequently repaid in cash could not be equated to cash consideration for s. 118.1(13)(c) purposes

The appellant estate donated shares of a private company (Edmette), which were non-qualifying securities, to a private foundation with which it...

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Words and Phrases
consideration receive payment

CAE Inc. v. The Queen, 2021 CCI 57, aff'd 2022 CAF 178

loan with non-commercial terms was government assistance when advanced

CAE, which was engaged in manufacturing flight simulator systems, incurred over $700 million in R&D expenditures on further developing such...

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Words and Phrases
receive
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 127 - Subsection 127(9) - Government Assistance an unconditionally repayable loan with a 2.5% yield was government assistance 312
Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract advance labelled by government as a "contribution" but unconditionally repayable was a loan 97

Borealis Geopower Inc. v. The Queen, 2018 TCC 189 (Informal Procedure)

taxpayer had “physically” received unearned government assistance because it had authority to deal with the funds

The taxpayer, a privately owned Canadian corporation involved in geothermal power exploration, development and utilization in Canada, was paid...

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Words and Phrases
receive
Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt taxpayer had "physically" received govenment assistance funds with freedom to transfer 109
Tax Topics - Income Tax Act - Section 162 - Subsection 162(11) loss carryback did not reduce late-filing penalty or interest 278

Blais v. MNR, 92 DTC 1497 (TCC)

A taxpayer was ordered in 1984 to retain arrears of alimentary allowance that had accumulated from March 1983 onward to be applied against an...

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Words and Phrases
receive
Locations of other summaries Wordcount
Tax Topics - General Concepts - Payment & Receipt payment references funds transfer 100
Tax Topics - Income Tax Act - Section 60 - Paragraph 60(b) 100

Mbarga v. The Queen, 2005 DTC 1447, 2005 TCC 595 (Informal Procedure)

An amount paid by Alberta Human Resources and Employment directly to the University of Calgary to enable the taxpayer to take a technology program...

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Words and Phrases
receive bursary

The Queen v. British Columbia Forest Products Ltd., 85 DTC 5577, [1986] 1CTC 1 (FCA)

"Parliament has expressly contemplated that a taxpayer may 'receive' assistance from a government in the form of a 'deduction from tax.'" The...

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Words and Phrases
receive
Locations of other summaries Wordcount
Tax Topics - Statutory Interpretation - Context 87

Canada v. Innovative Installation Inc., 2010 DTC 5175 [at 7317], 2010 FCA 285

indirect receipt through debt repayment

In order to ensure payment of a loan owing by the taxpayer ("Innovative") to a bank (RBC) on the death of Innovative's principal (Mr Peacock),...

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Words and Phrases
receive
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account receipt of insurance proceeds through debt repayment 156