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

Full-text translations of the French technical interpretation released last week, and of a further five items from the October 10, 2014 APFF Roundtable, are listed and briefly described in the table below.

These (and the other translations covering the last 32 months of CRA releases) are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for August.

Bundle Date Translated severed letter Summaries under Summary descriptor
2017-07-26 28 June 2017 External T.I. 2016-0653921E5 F - Beneficiary/person beneficially interested Income Tax Act - Section 70 - Subsection 70(3) a testamentary trust could be a beneficiary or beneficially interested in an estate
Income Tax Act - Section 248 - Subsection 248(25) testamentary trust could be considered to have a right as beneficiary in estate
2014-12-10 10 October 2014 APFF Roundtable, 2014-0534821C6 F - Question 2 - APFF Round Table Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(l) non-resident transferor must obtain SIN
10 October 2014 APFF Roundtable Q. 4, 2014-0534831C6 F - 2014 APFF Roundtable, Q. 4 - Late-filed 86.1 election & 220(3.5) penalty Income Tax Act - Section 86.1 - Subsection 86.1(2) general principles applied to relief of s. 86.1 late-election penalties
10 October 2014 APFF Roundtable Q. 4, 2014-0538231C6 F - 2014 APFF Roundtable, Q. 4 - Beneficially interested Income Tax Act - Section 248 - Subsection 248(25) legatee by particular title is included notwithstanding priority over heirs
10 October 2014 APFF Roundtable Q. 19, 2014-0538041C6 F - 2014 APFF Roundtable, Q. 19 - Stock dividend Income Tax Act - Section 74.4 - Subsection 74.4(2) non-application to stock dividend, cf. s. 86 reorg
Income Tax Regulations - Regulation 6205 - Subsection 6205(2) purpose test in Reg. 6205(2)(a) is not necessarily accomplished by all estate freezes/"arrangement" broad
Income Tax Act - Section 15 - Subsection 15(1.1) not engaged if stock dividend is proportional
Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) SI apportionment to stock dividend prefs
10 October 2014 APFF Roundtable Q. 21, 2014-0538091C6 F - 2014 APFF Roundtable, Q. 21 - Impact of the Descarries Case Income Tax Act - Section 245 - Subsection 245(4) Descarries failed to recognize scheme against indirect surplus stripping
Income Tax Act - Section 248 - Subsection 248(28) will not impose double taxation under s. 84(2) and (3)
Income Tax Act - Section 84 - Subsection 84(2) Descarries failed to recognize breadth of s. 84(2)