Two further translated Technical Interpretations are available
28 February 2018 - 2:39am
Email this ContentThe table below provides descriptors and links for two technical interpretations released in December 2013 as fully translated by us.
These (and the other full-text translations covering the last 50 months of CRA releases) are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for March.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2013-12-18 | 26 November 2013 External T.I. 2012-0449631E5 F - Amount deductible under paragraph 20(1)(e.2) | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.2) | reduction of deductible premium amount re pledged policy where net cost of pure insurance (“NCPI”) is lower than premiums |
| 15 November 2013 Internal T.I. 2013-0478621I7 F - Transfer of intangibles - TP adjustments | Income Tax Act - Section 247 - New - Subsection 247(2) | group sale with Canco not charging for intangibles should engage s. 247(2) | |
| Income Tax Act - Section 56 - Subsection 56(2) | secondary adjustment re group sale with Canco not charging for intangibles | ||
| Income Tax Act - Section 69 - Subsection 69(4) | s. 69(4) inapplicable where grandchild Canco undercharges for asset sale, enhancing sales proceeds received by ultimate U.S. parent |