Six further full-text translations of Technical Interpretations are available

25 April 2017 - 10:43pm
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Full-text translations of the two French technical interpretations that were released last week and of four French technical interpretations released between April 22, 2015 and April 8, 2015, are listed and briefly described in the table below.

These (and the other translations covering the last two years of CRA releases) are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for May.

Bundle Date Translated severed letter Summaries under Summary descriptor
2017-04-19 14 March 2017 External T.I. 2016-0627311E5 F - Deduction of contribution to an IPP or RCA Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangements a mooted RCA providing supplementary pension benefits must be similar to the IPP which it supplements
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(q) non-deductibility if supplementary benefits do not merely proportionately top-up IPP benefits
13 March 2017 External T.I. 2016-0626641E5 F - Election - Subsection 1101(5b.1) Reg. Income Tax Regulations - Regulation 1101 - Subsection 1101(5b.1) only one Reg. 1101(5b.1) election is required where work on an addition to a non-residential building extends over more than one year
Income Tax Regulations - Regulation 1102 - Subsection 1102(23) further work on an addition does not fall into a separate class
2015-04-22 15 January 2015 External T.I. 2014-0548101E5 F - Sens de "fabrication ou transformation" Income Tax Act - Section 125.1 - Subsection 125.1(3) - manufacturing or processing steel rod plating could qualify
Income Tax Regulations - Schedules - Schedule II - Class 29 “primarily” based on the fraction of time used in the qualifying activities
13 November 2014 External T.I. 2014-0536881E5 F - Bien agricole admissible - Boisé Income Tax Act - 101-110 - Section 110.6 - Paragraph 110.6(1.3)(c) disjunctive application of tests for pre-1987 property
2015-04-15 13 January 2015 Internal T.I. 2013-0497361I7 F - Services performed by a foreign affiliate Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(b) prototype testing services not directly related to sales of improved product
Income Tax Act - Section 95 - Subsection 95(3) - Paragraph 95(3)(d) prototype testing services not manufacturing
2015-04-08 16 December 2014 External T.I. 2014-0539841E5 F - Testamentary Trust Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(a) subsequent will-directed transfer from spousal trust to residue trust occurred as consequence of death
Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Testamentary Trust transfer from one testamentary trust to another pursuant to a will direction treated as a non-tainting contribution from the deceased