6 more translated CRA interpretations are available

We have published a translation of a CRA interpretation released last week and a further 5 translations of CRA interpretations released in March, 2011. Their descriptors and links appear below.

These are additions to our set of 1,063 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¾ years of releases of Interpretations 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
2020-01-08 12 November 2019 External T.I. 2019-0822161E5 F - T5008 Statement of Securities Transactions Income Tax Regulations - Regulation 230 - Subsection 230(1) - Sale a contribution of shares to a TFSA is not a “sale” for Reg. 230 purposes
Income Tax Regulations - Regulation 230 - Subsection 230(2) transfer of listed shares from taxable brokerage account to individual’s TFSA did not generate T5008 reporting requirement
2011-03-11 8 October 2010 Roundtable, 2010-0373621C6 F - Utilisation abusive des fiducies familiales Income Tax Act - Section 245 - Subsection 245(4) examples of the abusive use of family trusts engaging GAAR
11 February 2011 External T.I. 2010-0386651E5 F - Admissibilité - Frais médicaux Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(o) pathology expenses paid to physician would qualify
Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(a) preliminary report of genetic counsellor would not qualify
8 October 2010 APFF Roundtable, 2010-0373301C6 F - Classes of shares with identical characteristics Income Tax Act - Section 89 - Subsection 89(1) - Paid-Up Capital identical but separate QBCA classes would have separate PUC
Income Tax Act - Section 47 - Subsection 47(1) shares of identical but separate QBCA classes are identical properties unless their PUC rights differ
8 October 2010 APFF Roundtable Q. 11, 2010-0373281C6 F - Redemption of shares and eligible dividend Income Tax Act - Section 89 - Subsection 89(14) specific dollar amount required for regular dividends, but not for deemed dividend
2011-03-04 3 February 2011 External T.I. 2010-0389601E5 F - Allocation de transport Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit allowance from school in “consideration” for arranging child transport was non-taxable