Full translations of French severed letters released on December 2, 2015 are available

Full-text translations of five French technical interpretations released on December 2, 2015 are now available - and are listed and briefly described in the table below.

These (and the other translations covering the last 14 months of CRA releases) are subject to the usual (3 working weeks per month) paywall. You currently are in the “open” week for February.

Bundle Date Translated severed letter Summaries under Summary descriptor
2015-12-02 2 November 2015 External T.I. 2014-0558991E5 F - Loan from an Amateur Athlete Trust Income Tax Act - Section 143.1 - Subsection 143.1(1.2) - Paragraph 143.1(1.2)(d) genuine loan to athlete with adequate prospect of repayment not a transfer of property
15 December 2014 Internal T.I. 2012-0445361I7 F - Remboursement de frais de déménagement Income Tax Act - Section 2 - Subsection 2(1) criteria for determining “ordinarily resides” under s. 62 (coterminous with “ordinarily resident” under s. 250(3)
Income Tax Act - Section 248 - Subsection 248(1) - Eligible Relocation expenses re selling a Canadian home after a 2nd relocation abroad are non-deductible if no ordinary residence at 1st location abroad
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) reimbursement of moving expenses not a taxable benefit if such moving expenses otherwise deductible under s. 62 which, in the case of multiple moves, can turn on whether there is ordinary residence at each location
15 December 2014 Internal T.I. 2014-0544121I7 F - Chantier particulier Income Tax Act - Section 6 - Subsection 6(6) work engagement ceased to be temporary based on a change in circumstances
4 March 2015 Internal T.I. 2014-0527751I7 F - Soutien de revenu accordé aux individus Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(r) includes amounts received under the active employment measures of Emploi-Québec
18 February 2015 External T.I. 2012-0471731E5 F - Déductibilité du droit d’usage pour automobile Income Tax Act - Section 6 - Subsection 6(2) no reduction in benefit amount for benefits provided by employee to employer
Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) reduced auto enjoyment not an expenditure