6 further full-text translations of CRA interpretations are available

1 May 2018 - 11:11pm
Email this ContentEmail this Content

The table below provides descriptors and links for the Technical Interpretation released last week and for 5 of the October 2017 Financial Strategies and Instruments APFF Roundtable questions and answers, as fully translated by us.

These (and the other full-text translations covering the last 4 1/2 years of CRA releases) are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for May.

Bundle Date Translated severed letter Summaries under Summary descriptor
2018-04-25 12 June 2017 Internal T.I. 2016-0679291I7 F - Régime d’assurance décès et mutilation accidentels Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e.1) the payment of group accident plan premiums by an employer for its benefit gave rise to taxable benefits
2018-04-11 6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 1, 2017-0705221C6 F - Property transfers - common law partners in Québec Income Tax Act - Section 146 - Subsection 146(16) - Paragraph 146(16)(b) a common-law partners’ separation agreement can engage s. 146(16)(b) or 146.3(14) rollover even if technically they have no legal rights to settle
Income Tax Act - Section 73 - Subsection 73(1.01) - Paragraph 73(1.01)(b) rollover under common-law partners' separation agreement irrespective of whether technically they have separation rights to settle
Income Tax Act - Section 146.3 - Subsection 146.3(14) rollover pursuant to common-law partners' settlement agreement
6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 2, 2017-0710681C6 F - Withdrawal of RRSP over-contributions after death Income Tax Act - Section 146 - Subsection 146(8.8) income inclusion under s. 146(8.8) on death irrespective whether premiums exceeded deductible amount
Income Tax Act - Section 146 - Subsection 146(8.2) deemed s. 146(8.8) benefit on death treated as RRSP withdrawal, and executor should not use Form T746
6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 4, 2017-0707781C6 F - Withdrawal of undeducted RRSP contributions Income Tax Act - Section 146 - Subsection 146(8.2) s. 146(8.2) deduction for withdrawing excess contributions can be available even where Pt X.1 tax is not applicable
6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 5, 2017-0707801C6 F - RRIF transfers – partition of family patrimony Income Tax Act - Section 146.3 - Subsection 146.3(14) amount paid to surviving spouse's RRIF did not qualify under s. 146.3(14)
Income Tax Act - Section 146.3 - Subsection 146.3(1) - Designated Benefit payment from a deceased’s RRIF to the RRIF of the surviving spouse who was excluded under the will qualified as designated benefit
Income Tax Act - Section 60 - Paragraph 60(l) transfer from deceased's RRIF to RRIF of surviving spouse in settlement of claim
6 October 2017 APFF Financial Strategies and Financial Instruments Roundtable Q. 6, 2017-0707791C6 F - RRIF - Successive Deaths Income Tax Act - Section 146.3 - Subsection 146.3(1) - Designated Benefit death of the surviving spouse before she received payment of the testator’s legacy of his RRIF precluded access to the designated benefit rules
Income Tax Act - Section 146.3 - Subsection 146.3(6.1) s. 146.3(6.1) did not apply as the executor did not receive the RRIF legacy