6 further full-text translations of CRA interpretations are available

We have published a further 6 translations of interpretations released in August and July 2012. Their descriptors and links appear below.

These are additions to our set of 783 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 2/3 years of releases by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2012-08-24 30 July 2012 Internal T.I. 2012-0436711I7 F - Reassessment beyond the normal reassessment period Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) CRA could reassess beyond normal reassessment period based solely on an ARQ audit report showing error and carelessness of the taxpayer
2012-08-10 3 July 2012 External T.I. 2012-0443421E5 F - 84.1 and partnership Income Tax Act - Section 245 - Subsection 245(4) s. 245(2) has been applied to the use of a partnership to avoid s. 84.1
Income Tax Act - Section 84.1 - Subsection 84.1(1) use of partnership to avoid s. 84.1 could be attacked through challenge to partnership validity or applying s. 245(1) re circumvention of s. 84.1
13 July 2012 External T.I. 2012-0443281E5 F - DPA- véhicule dans le cadre d'un bien locatif Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) CCA could be claimable on motor vehicle used to earn rental income
2012-07-20 9 July 2012 External T.I. 2012-0438751E5 F - Police d'assurance-vie Income Tax Act - Section 148 - Subsection 148(9) - Proceeds of Disposition proceeds of disposition arise when policy settled and are calculated by insurer
Income Tax Act - Section 237 - Subsection 237(1.1) provision of SIN by holder of matured policy to insurer is required
2012-07-06 28 June 2012 External T.I. 2011-0427871E5 F - Application des paragraphes 98(3) 98(5) et 73(1) Income Tax Act - Section 73 - Subsection 73(1) s. 73(1) available on transfer of undivided interest from one separate spouse to the other following s. 98(3) wind-up of their rental partnership
Income Tax Act - Section 98 - Subsection 98(5) rental operation generating property income is a business for s. 98(5) purposes
26 June 2012 External T.I. 2011-0417391E5 F - Bien remis à une fiducie Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Testamentary Trust being a contingent beneficiary of an inter vivos trust disqualified a testamentary trust as such
Income Tax Act - Section 248 - Subsection 248(25) testamentary trust that was included in the class of potential beneficiaries of a discretionary inter vivos trust was a beneficiary