Seven further full-text translations of CRA technical interpretations/Roundtable items are available

28 June 2017 - 1:09am
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Full-text translations of the five French technical interpretations released last week and of two (APFF) Roundtable item that were released on January 14, 2015, are listed and briefly described in the table below.

These (and the other translations covering the last 29 months of CRA releases) are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for July.

Bundle Date Translated severed letter Summaries under Summary descriptor
2017-06-21 11 May 2017 External T.I. 2016-0679751E5 F - TFSA - Exempt Contribution Income Tax Act - Section 207.01 - Subsection 207.01(1) - Exempt Contribution - Paragraph (b) a “survivor payment” can be made out of the deceased’s TFSA even where this occurs in the executor’s discretion
Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(a) legacy made by executor exercising discretion conferred under will occurred because of death
10 May 2017 External T.I. 2017-0687051E5 F - Addition to ACB of a partnership interest Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) no s. 53(1)(e) addition for s. 34.2(2) stub period income inclusion
Income Tax Act - Section 34.2 - Subsection 34.2(2) no partnership-interest ACB addition for inclusion
12 May 2017 External T.I. 2016-0649841E5 F - Dividend Refund to Private Corporation Income Tax Act - Section 129 - Subsection 129(1) - Paragraph 129(1)(a) CRA automatically pays available dividend refunds even when not claimed (or wanted)
9 March 2017 External T.I. 2016-0680071E5 F - Règles transitoires - immobilisations admissibles Income Tax Act - Section 13 - Subsection 13(38) - Paragraph 13(38)(d) s. 13(38)(d)(iii) election can be available notwithstanding that only a minor pre-2017 ECE was incurred
29 May 2017 External T.I. 2014-0537111E5 F - Consequential assessment Income Tax Act - Section 152 - Subsection 152(4.3) reassessing to increase closing inventory permits a s. 152(4.3) reassessment to change the taxes payable "balance" for the following year
Income Tax Act - Section 10 - Subsection 10(2) reassessing to increase closing inventory permits reassessment to increase next year's COS
2015-01-14 10 October 2014 APFF Roundtable, 2014-0538121C6 F - Détermination de la JVM des actions General Concepts - Fair Market Value - Shares deferred tax liabilities not factored into share FMV
10 October 2014 APFF Roundtable, 2014-0538101C6 F - Avantage automobile en vertu de 15(5) Income Tax Act - Section 15 - Subsection 15(1.4) - Paragraph 15(1.4)(c) no double taxation to shareholder re employment auto benefit conferred on son