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

18 July 2017 - 11:07pm
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Full-text translations of the three French technical interpretations released last week, and of the three (APFF) Roundtable item released on December 30 and 23, , 2015 are listed and briefly described in the table below.

These (and the other translations covering the last 31 months of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2017-07-12 6 April 2017 External T.I. 2016-0658841E5 F - Purpose tests and Allocation of safe income Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) safe income was allocated between 2 classes of participating shares pro rata to their dividend entitlements
Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(b) s. 55(2) did not apply to dividends paid only for asset protection and QSBC-status purposes
21 November 2016 Internal T.I. 2016-0675761I7 F - Obligation de produire un T4A Income Tax Regulations - Regulation 200 - Subsection 200(1) artists’ union must issue T4A slips to incorporated artists respecting benefits received from the union
6 June 2017 External T.I. 2015-0617331E5 F - TFSA - Exempt Contribution Income Tax Act - Section 207.01 - Subsection 207.01(1) - Exempt Contribution - Paragraph (b) payment of family-law debt out of TFSA to surviving spouse would occur as a consequence of the deceased’s death
Income Tax Act - Section 248 - Subsection 248(23.1) - Paragraph 248(23.1)(a) payment of family-law obligation of deceased to surviving spouse out of deceased's TFSA could qualify
Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(a) legacy of residue (which included the residence) could be satisfied with TFSA of deceased
2014-12-30 10 October 2014 APFF Roundtable, 2014-0538241C6 F - 75(2) and definition of "earned income" in 146(1) Income Tax Act - Section 75 - Subsection 75(2) character preservation of attributed income/basis adjustment for denied capital loss at trust level
Income Tax Act - Section 146 - Subsection 146(1) - Earned Income character preservation of s. 75(2) attributed income
Income Tax Act - Section 40 - Subsection 40(3.6) basis adjustment for denied capital loss (otherwise subject to s. 75(2) attribution) at trust level
2014-12-23 10 October 2014 APFF Roundtable, 2014-0538261C6 F - Disposition of capital interest/personal trust Income Tax Act - 101-110 - Section 107 - Subsection 107(2) issuance of note by trust is not distribution of trust property
Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Cost Amount note issuance is not trust property distribution to a beneficiary
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) non-deductible interest on note issued to beneficiary
10 October 2014 APFF Roundtable, 2014-0538221C6 F - Day Trading in RRSP Income Tax Act - Section 146 - Subsection 146(4) RRSP/RRIF day-trading of qualified investments is exempt