Six further translated technical interpretations are available
4 October 2017 - 12:54am
Email this ContentFull-text translations of the six technical interpretation released between June 18, 2014 and June 4, 2014, are listed and briefly described in the table below.
These (and the other translations covering the last 40 months of CRA releases) are subject to the usual (3 working weeks per month) paywall. You are currently in the “open” week for October.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2014-06-18 | 20 May 2014 External T.I. 2013-0516121E5 F - Debt forgiveness | Income Tax Act - Section 12 - Subsection 12(2.2) | s. 12(1)(x)(iv) inclusion from BIA settlement of GST interest and penalties could be offset against related expense |
| Income Tax Act - Section 248 - Subsection 248(26) | unremitted GST and QST were not obligation "issued" by debtor | ||
| Income Tax Act - Section 80 - Subsection 80(1) - Commercial Debt Obligation | BIA settlement of unremitted GST interest | ||
| Income Tax Act - Section 9 - Forgiveness of Debt | BIA settlement of unremitted GST on sales was on capital account | ||
| Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv) | BIA settlement of GST interest and penalties included under s. 12(1)(x)(iv) | ||
| 28 May 2014 External T.I. 2013-0486111E5 F - RRSP, prohibited investment | Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage | no advantage on s. 51 exchange | |
| Income Tax Act - Section 207.01 - Subsection 207.01(13) | s. 51 exchange of transitional prohibited property does not trigger s. 207.04(1) tax | ||
| Income Tax Act - Section 207.05 - Subsection 207.05(4) | s. 207.05(4) status is preserved following s. 51 exchange | ||
| 2014-06-04 | 12 May 2014 External T.I. 2013-0503531E5 F - Discretionary Dividends Shares | Income Tax Act - Section 85 - Subsection 85(1.3) | grandchild wholly owned by individual directy and through immediate subsidiary is wholly-owned corporation |
| 22 May 2014 External T.I. 2014-0519811E5 F - Droit d'usage au Québec pré-1991 | General Concepts - Ownership | usufructuary of duplex unit was de facto owner thereof | |
| Income Tax Act - Section 248 - Subsection 248(3) | effective grandfathering of right as usufructuary which arose before 1991 | ||
| Income Tax Act - Section 54 - Principal Residence | usufructuary of duplex unit (with her right acquired pre-1991) entitled to claim principal residence exemption on post-1991 disposition | ||
| 20 May 2014 External T.I. 2014-0517331E5 F - CII - exploitation agricole | Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (c) | test is of intention on acquisition to use over 50%, during months of likely use during the equipment’s lifetime, on farm in the region | |
| Income Tax Act - Section 127 - Subsection 127(27) | no ITC reversal if unanticipated transfer of equipment to a farm outside the region | ||
| General Concepts - Ownership | co-owners entitled to pro rata ITCs | ||
| 14 November 2013 Internal T.I. 2013-0485331I7 F - REÉR et revenu d'un Indien | Other Legislation/Constitution - Federal - Indian Act - Section 87 | RPP benefits exempt if contributions exempt/RRSP withdrawals exempt if contributions not deductible |