Six further full-text translations of CRA interpretations are available
13 March 2018 - 1:27am
Email this ContentThe table below provides descriptors and links for a French technical interpretation released in November 2013 and five questions from the October 2013 APFF Roundtables, as fully translated by us.
These (and the other full-text translations covering the last 4 1/3 years of CRA releases) are subject to the usual (3 working weeks per month) paywall.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2013-12-04 | 11 October 2013 Roundtable, 2013-0495801C6 F - Dividend Paid to Trust and Schedule 3 of T2 | Income Tax Act - 101-110 - Section 104 - Subsection 104(19) | s. 104(19) designation is not effective until year end of trust |
| Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b) | s. 104(19)-designated dividend is not received for s. 186(1)(b) purposes until year end of trust | ||
| 11 October 2013 APFF Roundtable, 2013-0495811C6 F - De Facto Control | Income Tax Act - Section 256 - Subsection 256(5.1) | statutory right of chair to tie-breaking vote does not per se confer de facto control | |
| 2013-11-27 | 29 October 2013 External T.I. 2013-0489771E5 F - Internal Reorganization - 55(3)(a) | Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(v) | relief under s. s. 256(7)(a)(i)(C) or (D) is relevant to s. 55(3.1)(b)(ii), but not to ss. 55(3)(a)(i) to (v) |
| Income Tax Act - Section 248 - Subsection 248(10) | estate distribution of corporation followed by transfer of assets from related corporation could be part of same series | ||
| Income Tax Act - Section 55 - Subsection 55(3.2) - Paragraph 55(3.2)(d) | s. 55(3.2)(d) application to estate distribution of corporation to 3 sibling beneficiaries does not deem them to be related to each other | ||
| 11 October 2013 Roundtable, 2013-0495281C6 F - Question 9 - APFF Round Table | Income Tax Act - Section 146.3 - Subsection 146.3(6.1) | transfer of RRIF by executor to RRIF of surviving spouse | |
| Income Tax Act - Section 212 - Subsection 212(1) - lParagraph 212(1)(q) | direct transfer to RRIF of surviving non-resident spouse | ||
| Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(l) | transfer to RRSP or RRIF of surviving non-resident spouse: SIN required; payment can be made directly to RRSP/RRIF of surviving spouse in accordance with joint instructions even where no specific non-will designation is made | ||
| Income Tax Act - Section 146 - Subsection 146(8.1) | deemed receipt of refund of premiums for amount paid to executor, with deemed benefit to recipient spouse | ||
| 11 October 2013 APFF Roundtable, 2013-0493651C6 F - Affiliated persons and de facto control | Income Tax Act - Section 256 - Subsection 256(5.1) | holding of relatively large note where debtor has a iliquid business could give rise to de facto control | |
| Income Tax Act - Section 40 - Subsection 40(3.61) | exception unavailable for inter vivos trust | ||
| 11 October 2013 APFF Roundtable, 2013-0495781C6 F - GRIP Exceeds Safe Income | Income Tax Act - Section 89 - Subsection 89(1) - Excessive Eligible Dividend Designation | detailed review required to determine whether creation of preferred share dividend to flow out GRIP in excess of SIOH generatd EEDD |