Six further full-text translations of CRA interpretations are available
14 August 2018 - 8:21am
Email this ContentThe table below provides descriptors and links for six Interpretation released in May 2013, as fully translated by us.
These (and the other full-text translations covering all of the 621 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.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2013-05-15 | 23 November 2012 External T.I. 2012-0449101E5 F - Production exclue - CIPCMC | Income Tax Regulations - Regulation 1106 - Subsection 1106(1) - Excluded Production - Paragraph (a) - Subparagraph (a)(iii) - Clause (a)(iii)(A) | 5-year test was violated when successor to production company became controlled by an unrelated person |
| 13 September 2012 Internal T.I. 2012-0442671I7 F - Dédommagement pour la perte de bénéfices | Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit | damages received for loss of life insurance coverage were not rendered a death benefit under the surrogatum principle | |
| Income Tax Act - Section 6 - Subsection 6(3) | damages received by former employees of insolvent company for cancellation of their life insurance coverage were received in lieu of remuneration for their employment services | ||
| Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(b) | legal fees paid to recover damages for employer cancellation of insurance coverage, and medical plan, qualifed and did not qualify, respectively | ||
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | damages received after 2011 by employees of an insolvent company for cancellation of their medical plan have become taxable | ||
| 6 December 2012 External T.I. 2012-0461711E5 F - Paiements indirects / Indirect payments | Income Tax Act - Section 56 - Subsection 56(2) | 56(2) inapplicable to incorporated artist respecting producer paying mandatory contributions to the fund for the artist’s union | |
| Income Tax Regulations - Regulation 200 - Subsection 200(1) | no T4A slip to be issued by producer paying mandatory contributions to the fund for the union of the artist whose corporation receives fees from the producer | ||
| 18 April 2013 Internal T.I. 2013-0485481I7 F - Balance of sale price without interest | Income Tax Act - Section 16 - Subsection 16(1) | s. 16(1) inapplicable if sale price including non-interest bearing balance does not exceed sold assets’ FMV | |
| 21 January 2013 Internal T.I. 2012-0442021I7 F - Assessing 163(2) penalty | Income Tax Act - Section 163 - Subsection 163(2) - Paragraph 163(2)(c.2) | penalty is computed on total RMES adjustment, not just the false portion | |
| Income Tax Act - Section 163 - Subsection 163(2) - Paragraph 163(2)(c) | false RMES claim by husband does not generate any penalty for resulting overstatement of CCTB, WITB and GSTC by wife, assuming she made no false statement | ||
| Income Tax Act - Section 163 - Subsection 163(2) - Paragraph 163(2)(a) - Subparagraph 163(2)(a)(i) | deduction against increase to income attributable to a false statement can be reduced by QPP contribution increase or by discretionary CCA claim that is wholly related to that income source | ||
| 20 March 2013 Internal T.I. 2012-0463181I7 F - Revenu des entrepreneurs | Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | completion method unavailable for communication and electricity structure installations |