Six further translated technical interpretations are available
Full-text translations of the technical interpretation released last week and of the five released between August 20, 2014 and July 30, 2014, are listed and briefly described in the table below.
These (and the other translations covering the last 38 months of CRA releases) are subject to the usual (3 working weeks per month) paywall.
|Bundle Date||Translated severed letter||Summaries under||Summary descriptor|
|2017-09-06||28 October 2016 External T.I. 2016-0654331E5 F - Transfer of rights to income||Income Tax Act - Section 9 - Nature of Income||where rental lands purchased subject to obligation to pay the rents to vendor, rents did not have quality of income to purchaser under s. 9|
|Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense||where rental lands purchased subject to obligation to pay the rents to vendor, no income inclusion and deduction of the rents by the purchaser under ss. 9 and 18(1)(a)|
|Income Tax Act - Section 56 - Subsection 56(4)||where rental lands purchased subject to obligation to pay the rents to NAL vendor, s. 56(4) trumps s. 9 to include rents in purchaser’s income|
|Income Tax Act - Section 56 - Subsection 56(2)||s. 56(2) could apply to shareholder of purchaser of lands if vendor did not pay FMV consideration for retaining rights to rents|
|2014-08-20||7 July 2014 External T.I. 2014-0518561E5 F - Superficial loss||Income Tax Act - Section 54 - Superficial Loss||shares of Holdco as identical property to shares of Opco/transferred corporation wound-up but not dissolved within 30 days|
|Income Tax Act - Section 88 - Subsection 88(1)||transferred corporation wound-up but not dissolved within 30 days|
|27 June 2014 External T.I. 2013-0500701E5 F - Déductibilité de certaines dépenses||Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose||distinction between principal and secondary reason for incurring expense|
|2014-08-13||27 June 2014 External T.I. 2013-0498191E5 F - Interaction entre 55(2) et l'impôt de partie IV||Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b)||Part IV tax on cross-redemptions takes into account the Part I tax (and RDTOH addition) generated by s. 55(2) application thereto|
|Income Tax Act - Section 55 - Subsection 55(2)||s. 55(2) tax on cross-redemption deemed dividends between connected CCPCs gave rise to circular Part IV tax|
|2 July 2014 External T.I. 2014-0529731E5 F - Stop-loss Rules||Income Tax Act - Section 40 - Subsection 40(3.4)||taxpayer able to designate sourcing of disposed-of shares/illustration of application of CRA formula|
|2014-07-30||9 July 2014 External T.I. 2014-0527591E5 F - Résidence principale||Income Tax Act - Section 54 - Principal Residence - Paragraph (a)||housing unit rented to son and unrelated roommate potentially could qualify as principal residence|