Further full-text translations of severed letters from July 2015 are available
Full-text translations of six technical interpretations released in French between July 29, 2015 and June 30, 2015 are now available - and are listed and briefly described in the table below.
These (and the other translations covering the last 20 months of CRA releases) are subject to the usual (3 working weeks per month) paywall.
|Bundle Date||Translated severed letter||Summaries under||Summary descriptor|
|2015-07-29||4 November 2014 External T.I. 2014-0521211E5 F - Cartes-cadeau d'une chaîne de supermarchés||Income Tax Act - Section 67.1 - Subsection 67.1(1)||50% limitation applicable to gift cards exchangeable at supermarket|
|5 November 2014 External T.I. 2014-0521891E5 F - Résidence principale et copropriété||Income Tax Act - Section 40 - Subsection 40(4)||overview of s. 40(4) rule|
|General Concepts - Ownership||whether a tacit co-ownership agreement is respected is a private law issue|
|5 November 2014 External T.I. 2014-0529991E5 F - Avantage pour automobile-personne liée||Income Tax Act - Section 6 - Subsection 6(2)||standby charge computed based on cost to auto owner which is related to employer|
|Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i)||control of non-share corp references who can appoint board|
|2015-07-22||24 June 2015 External T.I. 2015-0575911E5 F - Benefit to shareholder or conferred on a person||Income Tax Act - Section 15 - Subsection 15(1.4) - Paragraph 15(1.4)(c)||benefit only conferred on one shareholder (the husband) if wife of one of four sibling shareholders receives benefit|
|Income Tax Act - Section 246 - Subsection 246(1)||benefit conferred on spouse of individual shareholder of parent|
|Income Tax Act - Section 56 - Subsection 56(2)||benefit conferred on spouse of individual shareholder of parent|
|2015-07-15||11 June 2015 External T.I. 2014-0522641E5 F - Usufruct||Income Tax Act - Section 73 - Subsection 73(3)||creation of usufruct between father and son entails transfer of trust interest, not farm property|
|Income Tax Act - 101-110 - Section 108 - Subsection 108(7)||creation of usufruct between father and son, resulting in deemed trust, did not entail property transfer to the deemed trust|
|Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property||termination of usufruct between father and son on farmland, which was a deemed trust, did not entail disposition of qualified farm property|
|2015-06-30||2 June 2015 External T.I. 2015-0570071E5 F - Attribution Rules Trust||Income Tax Act - Section 74.4 - Subsection 74.4(2)||application of s. 74.4(2) to family trust with minor beneficiaries after s. 51(1) freeze in favour of second family trust with same minor beneficiaries|