23 January 2023 External T.I. 2020-0865161E5 F - SSUC/CEWS – Sous-alinéa 125.7(4)e)(i) et personne -- summary under Paragraph 125.7(4)(e)

Regarding the time at which an amount is regarded as received by an eligible entity which has made an election under s. 125.7(4)(e)(i) to use the cash method in determining its qualifying revenues for CEWS purposes, where the amount is received by a third party before being paid to the eligible entity, CRA stated:

IT-433R … states [in subpara. 3(a)] that the meaning of the term "received" is broad enough to consider a taxpayer to have received an amount at the time that inter alia it was received by a person authorized to receive it on behalf of the taxpayer. …

[A] person entitled to receive an amount on behalf of a taxpayer for CEWS purposes may include a person who is entitled to receive the amount for a taxpayer by inter alia an agreement or by statute.

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