Five full-text translations of 2013 APFF Roundtable items and Technical Interpretations are available

20 February 2018 - 11:54pm
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The table below provides descriptors and links for two items from the October 2013 APFF Roundtable, as fully translated by us – as well as for three technical interpretations released in January 2014.

These (and the other full-text translations covering the last 4 years of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2014-01-15 15 October 2013 Internal T.I. 2013-0491951I7 F - Travaux en cours au moment du retrait d'un associé Income Tax Act - Section 34 no new s. 34 election required if s. 98(6) or (5) applies/election can be made in income reconciliation
12 November 2013 Internal T.I. 2013-0497611I7 F - Feuillet T1204 Income Tax Regulations - Regulation 237 - Subsection 237(2) T1204 disclosure applicable only where contract with federal supplier and includes travel reimbursements as “services” consideration
11 October 2013 APFF Roundtable, 2013-0496511C6 F - Actions prescrites Income Tax Regulations - Regulation 6205 - Subsection 6205(2) simultaneous freezes by arm's length shareholders for their respective families to not qualify because the respective trusts/beneficiaries are not NAL with each freezor
11 October 2013 APFF Roundtable, 2013-0495691C6 F - Clause restrictive Income Tax Act - Section 56.4 - Subsection 56.4(1) - Eligible Interest must be one, rather than more than one, underlying corp
Income Tax Act - Section 56.4 - Subsection 56.4(3) - Paragraph 56.4(3)(c) non-solicitation clause/divergence of covenanter and seller
Income Tax Act - Section 56.4 - Subsection 56.4(7) - Paragraph 56.4(7)(b) non-solicitation clause could be treated as part of a non-compete
Income Tax Act - Section 56.4 - Subsection 56.4(7) - Paragraph 56.4(7)(f) maintenance of Holdco fmv/divergence of seller and covenanter
2014-01-08 10 December 2013 External T.I. 2013-0480771E5 F - Winding-Up of a Corporation Income Tax Act - Section 88 - Subsection 88(2) deemed year end under s. 88(2)(a)(iv) is only for surplus computation purposes