Six further full-text translations of CRA interpretations are available

The table below provides descriptors and links for a French Technical Interpretation released in November 2013 and for 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. You are currently in the “open” week for April.

Bundle Date Translated severed letter Summaries under Summary descriptor
2013-11-13 25 September 2013 Internal T.I. 2013-0476311I7 F - 93(2), 93(2.01) - Share substituted Income Tax Act - Section 248 - Subsection 248(5) s. 248(5) requirement for a legal exchange is engaged by a reference to a substituted share
Income Tax Act - Section 93 - Subsection 93(2.01) concept of substituted share in s. 93(2.01) is subject to the exchanged-for limitation in s. 248(5)(a)
11 October 2013 Roundtable, 2013-0495741C6 F - Dividend received by an employee trust Income Tax Act - 101-110 - Section 104 - Subsection 104(19) s. 104(19) designation unavailable for employee trust or employee benefit trust
11 October 2013 Roundtable, 2013-0495891C6 F - Partnership's capital gains allocation - CGE Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) capital gains from CGD-eligible property are separately allocated to partner
11 October 2013 APFF Roundtable, 2013-0495751C6 F - Time of an Acquisition of Control Income Tax Act - Section 256 - Subsection 256(9) s. 256(9) does not permit the parties to elect as to the actual time of acquisition of control
11 October 2013 APFF Roundtable, 2013-0493691C6 F - Transfer of a Foreign Retirement Arrangement Income Tax Act - Section 60.01 2 transfers of IRAs or 401(k) would not be a series of periodic payments
11 October 2013 APFF Roundtable, 2013-0495821C6 F - Share disposition Income Tax Act - Section 248 - Subsection 248(1) - Disposition no disposition where shares exchanged for identical-attribute shares of a different class
Income Tax Act - Section 85 - Subsection 85(1) shares in different class with identical attributes are the same shares