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

9 January 2018 - 1:58am
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The table below provides descriptors and links for the French technical interpretation released last week and five technical interpretations released in February of 2014, as fully translated by us.

These (and the other full-text translations covering the last 3 ¾ years of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2018-01-03 30 August 2017 External T.I. 2017-0718311E5 F - Capital dividend account Income Tax Act - Section 83 - Subsection 83(3) a late s. 83(3) election causes a retroactive increase to the CDA of the corporate recipient of the dividend
Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (b) late capital dividend election retroactively affects CDA of dividend recipient
2014-02-19 18 December 2013 External T.I. 2013-0511101E5 F - Substantial interest - Part VI.1 Income Tax Act - Section 251.2 - Subsection 251.2(2) - Paragraph 251.2(2)(a) no acquisition of control where votes pass from trust to an estate with the same individuals as executors
Income Tax Act - Section 191 - Subsection 191(3) creation of substantial interest through redemption of special voting shares
Income Tax Act - Section 248 - Subsection 248(1) - Disposition no disposition of shares that became voting by operation of law (due to cancellation of voting shares)
Income Tax Act - Section 249 - Subsection 249(4) voting rights shifted to 2nd trust with same trustees: no control change
2014-02-12 3 January 2014 External T.I. 2013-0507541E5 F - Crowdfunding General Concepts - Agency whether a crowdfunding contribution is on-paid to a charity as agent for the contributor
15 January 2014 External T.I. 2013-0515651E5 F - Affiliated persons Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(d) control by a person is not control by a group of persons
Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(e) corporation is affiliated with partnership of which its controlling shareholder is a majority-interest partner
27 January 2014 External T.I. 2013-0504191E5 F - RRSP, qualified investment Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (a) annuitant's free use of property of corporation held by RRSP is an advantage
Income Tax Regulations - Regulation 4901 - Subsection 4901(2) - Specified small business corporation general discussion of SSBC definition
10 January 2014 External T.I. 2013-0506571E5 F - Subsections 15(2) and 15(2.6) Income Tax Act - Section 15 - Subsection 15(2.6) monthly shareholder advances partially repaid with annual dividends