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

The table below provides descriptors and links for six French technical interpretation released in April-May 2014, as fully translated by us.

These (and the other full-text translations covering the last 3 ½ years of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2014-05-07 2 April 2014 External T.I. 2014-0521041E5 F - Application de 13(7.1) Income Tax Act - Section 13 - Subsection 13(7.4) general requirements for s. 13(7.4) to apply
Income Tax Act - Section 13 - Subsection 13(7.1) no s. 13(7.4) election required where s. 13(7.1) applies
2 April 2014 External T.I. 2012-0473151E5 F - Limitation du coût de location d'un véhicule Income Tax Act - Section 67.3 GST ITCs included under element E of formula
Income Tax Act - Section 248 - Subsection 248(16) GST ITCs constitute a “reimbursement” for car lease expense limitation purposes
11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options General Concepts - Fair Market Value - Options stock options with no in-the-money value could have nil FMV
Income Tax Act - Section 52 - Subsection 52(1) s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares
Income Tax Act - Section 15 - Subsection 15(1) double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder
Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder
Income Tax Act - Section 56 - Subsection 56(4) implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder
Income Tax Act - Section 248 - Subsection 248(28) s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15
Income Tax Act - Section 9 - Timing no s. 9(1) income inclusion from consultant being granted stock options until exercise
3 April 2014 External T.I. 2013-0512371E5 F - Qualification des montants gagnés au jeu de poker Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit on-line poker winnings were from more than a pastime
25 April 2014 External T.I. 2013-0515621E5 F - Frais de voyage / Travelling expenses Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) benefit where employer pays costs of friend to accompany employee on training trip
2014-04-30 27 March 2014 External T.I. 2014-0524851E5 F - Deemed year-end and CPCC status Income Tax Act - Section 249 - Subsection 249(3.1) Ekamant: s. 251(5)(b) does not vitiate actual control by share owner
Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) sub of public corporation does not become CCPC until time of its actual acquisition of control