CRA confirms its historical position on the meaning of “credited”

In response to brief questions as to how a Canadian corporation may recover Part XIII tax that it has withheld on a dividend cheque issued to a US resident that then is returned, CRA responded that this was a question that could be specifically addressed with more complete facts, and confirmed its position in IC 77-16R4, May 11, 1992 (Archived), on “credited”:

5. The words "credits" and "credited" cover any situation where a resident of Canada or, in certain cases, a non-resident (see 8 below) has set aside and made unconditionally available to the non-resident creditor an amount due to the non-resident such as where (a) a tenant or agent deposits rents in a bank account on behalf of a non-resident landlord; (b) a bank credits interest to the savings account of a non-resident; (c) an insurance or trust company deposits a pension or annuity payment in the bank account of a non-resident; or (d) the amount due is applied by the resident (or deemed resident) against an amount owing by the non-resident. …

Neal Armstrong. Summary of 19 November 2019 Roundtable, 2019-0829611C6 under s. 212(2).