Six further full-text translations of CRA interpretations are available
23 July 2018 - 11:39pm
Email this ContentThe 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 of the 603 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 |
|---|---|---|---|
| 2013-06-19 | 25 April 2013 Internal T.I. 2013-0478511I7 F - Distribution à un commanditaire | Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | real estate capital gains flowed through to limited partner retained character |
| Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | allocated capital gains retained their character unless re services performed by partner in course of separate business | ||
| Excise Tax Act - Section 272.1 - Subsection 272.1(1) | distinction between return on partnership investment and services rendered by partner in the course of a separate business | ||
| Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) | services rendered by limited partner to LP gave rise to ACB increase if no s. 9 income inclusion for fee income | ||
| 2013-06-12 | 24 April 2013 External T.I. 2013-0476561E5 F - Coûts de drainage de terre agricole | Income Tax Act - Section 30 | costs of installing drainage tile deductible by tenant farmer, not lessor |
| 31 May 2013 External T.I. 2013-0480431E5 F - Deduction from business investment loss | Income Tax Act - Section 39 - Subsection 39(10) | capital gains deduction previously claimed by individual re capital gain allocated by trust reduced BIL subsequently realized by each of individual and trust | |
| 10 May 2013 External T.I. 2012-0442791E5 F - SENC - Revenu d'entreprise exploitée activement | Income Tax Act - Section 129 - Subsection 129(6) | Norco applied to rent paid by Opco to partnership between Opco's Holdco and Holdco's shareholder's brother | |
| 2 May 2013 External T.I. 2013-0481361E5 F - Ordre de disposition d'actions AAPE | Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(a) | FIFO method is applied to determine which of ideintical shares were disposed of first | |
| 14 May 2013 External T.I. 2012-0469591E5 F - Capital dividend received by a trust and CDA | Income Tax Act - 101-110 - Section 104 - Subsection 104(20) | no recognition of capital dividend by corporate beneficiary where received by trust in Year 1 and distributed in Year 2 | |
| Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (g) | no addition for capital dividend received by trust in Year 1 and distributed in Year 2 to corporate beneficiary |