Over 600 translations of CRA French-language interpretations are available

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

These (and the other full-text translations covering all of the 609 French-language Interpretations released in the last 5 1/4 years by the Income Tax Rulings Directorate) are subject to the usual (3 working weeks per month) paywall. Next week is the "open" week for August.

Bundle Date Translated severed letter Summaries under Summary descriptor
2013-06-12 20 March 2013 External T.I. 2012-0442571E5 F - Coût d'acquisition d'un terrain Income Tax Regulations - Schedules - Schedule II - Class 8 cost of water and sewer lines connecting mobile home units, included in Class 8
Income Tax Act - Section 54 - Adjusted Cost Base cost of land acquired from developer equal to total barter value minus amounts allocated to Classes 8 and 17
9 January 2013 External T.I. 2010-0384221E5 F - Paiements indirects Income Tax Act - Section 56 - Subsection 56(2) cost of land acquired from developer equal to total barter value minus amounts allocated to Classes 8 and 17
14 February 2013 Internal T.I. 2011-0424341I7 F - Amounts forwarded to trustee/beneficiary Income Tax Act - Section 75 - Subsection 75(2) s. 75(2) not applicable to dividends on common shares issued to discretionary family trust on estate freeze
Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) did not apply to trustee/beneficiary of discretionary trust who directed income to her children and did not exercise discretion in her own favour
Income Tax Act - 101-110 - Section 104 - Subsection 104(13) income was received by children beneficiaries as agent for their mother
Income Tax Act - 101-110 - Section 104 - Subsection 104(6) - Paragraph 104(6)(b) Quebec discretionary trust with two named trustees but, in fact, only one trustee, would not be entitled to s. 104(6)(b) deductions
2013-06-05 12 February 2013 Internal T.I. 2012-0437211I7 F - NRT rules and subsection 164(6) Income Tax Act - Section 164 - Subsection 164(6) s. 94 deemed resident trust could carry back under s. 164(6) re capital loss on non-TCP shares
Income Tax Act - Section 54 - Personal-Use Property personal residence of deceased potentially would not be personal-use property to estate
Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(a) estate of resident deceased with one resident beneficiary was subject to s. 94(3)
2013-05-29 17 April 2013 External T.I. 2012-0457011E5 F - Coop Shares in RRSP and Prohibited Invest. Rules Income Tax Act - Section 207.01 - Subsection 207.01(1) - Excluded Property - Paragraph (c) shares can become prohibited investments as a result of other shareholders dispose of their shares
Income Tax Act - Section 207.04 - Subsection 207.04(4) dispositions that generate the refund are not limited to redemptions of the shares
Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (c) advantage tax on net capital gains and income of RRSP from cooperative shares
2013-05-15 5 April 2013 External T.I. 2012-0471151E5 F - Binding Agreement Income Tax Act - Section 9 - Computation of Profit side letter would not reduce owner’s entitlement to rents from property if not entered into at same time as property acquisition
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense counter letter payments non-deductible because Quebec counter letter entered into after apparent letter