Six further full-text translations of CRA technical interpretations are available
20 November 2017 - 11:41pm
Email this ContentThe 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 |