Six further full-text translations of CRA interpretations are available

The table below provides descriptors and links for six Interpretation released in June 2013, as fully translated by us.

These (and the other full-text translations covering all French-language Interpretations released in the last 5 years by the Income Tax Rulings Directorate) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2013-06-26 9 May 2013 External T.I. 2012-0435401E5 F - Server as a PE in a province Income Tax Regulations - Regulation 400 - Subsection 400(2) server (including leased server) in a province at disposal of the business and used in that business is PE
18 June 2013 External T.I. 2012-0433261E5 F - 55(5)(f) and Surplus Stripping Income Tax Act - Section 84 - Subsection 84(2) partial conversion of retained earnings to capital dividends through deliberate failure to make s. 55(5)(f) designation was abusive stripping
Income Tax Act - Section 245 - Subsection 245(4) deliberate engaging of s. 55(2) to convert annual taxable dividends into annual capital gains permitting annual capital dividends would engage s. 245(2)
20 February 2013 External T.I. 2012-0469811E5 F - Interest deductibility Income Tax Act - Section 18 - Subsection 18(2) interest subject to s. 18(2) must be calculated on a lot-by-lot basis
2013-06-19 29 April 2013 External T.I. 2013-0476131E5 F - Régime d'assurance-collective Income Tax Act - Section 6 - Subsection 6(4) general description of the s.6(4) exception to s. 6(1)(a)(i)
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e.1) overview of interrelationship between ss. 6(1)(a)(i), 6(1)(e.1) and 6(4)
7 May 2013 External T.I. 2013-0481321E5 F - Logement sécurisé - travail de nature temporaire Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) - Subpargraph 6(6)(a)(i) payment of rents by a foreign employer at a secure compound in another country could qualify except for after when employment ceased
10 May 2013 External T.I. 2012-0449651E5 F - SENC - revenu d'entreprise exploitée activement Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share assets used by an LP in its active business are used by its partner in an active business
Income Tax Act - Section 129 - Subsection 129(6) Norco followed