Fingold v. MNR, 92 DTC 2011, [1992] 2 CTC 2393 (TCC) -- summary under Investment Contract

By services, 28 November, 2015

Before finding that payments made by a corporation to its shareholder-employees constituted debts of the employees rather than representing advance distributions of share capital, and therefore were subject to s. 80.4(1), Rip J. stated (p. 2017):

"A debt is a sum payable in respect of a liquidated money demand. It does not include an unliquidated claim for damages. A debt is a sum of money owed in respect of which a plaintiff has a right to bring and maintain an action."

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