We have translated 6 more CRA interpretations

We have translated a further 6 CRA interpretations released in February of 2002. Their descriptors and links appear below.

These are additions to our set of 2,806 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 22 years of releases of such items by the Directorate. These translations are subject to our paywall (applicable after the 5th of each month).

Bundle Date Translated severed letter Summaries under Summary descriptor
2002-02-01 7 December 2001 Internal T.I. 2001-0108597 F - Crédit d'impôt emploi étranger Art. 122.3 Income Tax Act - Section 122.3 - Subsection 122.3(1) - Paragraph 122.3(1)(b) - Subparagraph 122.3(1)(b)(i) contract can be with a related person
Income Tax Act - Section 248 - Subsection 248(1) - Business there is a business if profit generated even if the activity was not undertaken primarily for the purpose of earning a profit
6 December 2001 Internal T.I. 2001-0110047 F - Revenu d'emploi organisation intern. Income Tax Act - Section 126 - Subsection 126(3) organization that brought together states, government agencies and non-governmental organizations did not qualify as an intergovernmental organization
2002-01-18 29 January 2002 External T.I. 2000-0053605 F - REVENU DES PECHEURS Income Tax Act - Section 9 - Nature of Income factors for allocating catch between individual holding fishing licence and his fishing corporation
11 February 2002 External T.I. 2001-0092975 F - MOMENT DE L'INCLUSION DANS LE REVENU Income Tax Act - Section 9 - Timing retroactive fee increases were not income until that date that the Order in Council ordering their payment took effect
6 February 2002 External T.I. 2001-0100565 F - CHANGEMENT D'USUAGE ET PERTE FINALE Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(a) change to personal use of assets on cessation of proprietorship could trigger terminal loss/ no application of s. 13(7)(a) if they are not used at all after the cessation
Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) change to personal use of assets on business termination engages ss. 45(1)(a) and 13(7)(a), but not if all use ceases
7 February 2002 External T.I. 2002-0118535 F - REMBOURSEMENT DE PRIMES - ENFANT MINEUR Income Tax Act - Section 146 - Subsection 146(1) - Refund of Premiums - Paragraph (b) financial dependence condition can be established even where child not living with parent