Six further full-text translations of CRA interpretations are available
The table below provides descriptors and links for six Interpretation released in April and March 2013, as fully translated by us.
These (and the other full-text translations covering all of the 633 French-language Interpretations released in the last 5 1/3 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 September.
|Bundle Date||Translated severed letter||Summaries under||Summary descriptor|
|2013-04-24||20 March 2013 Internal T.I. 2013-0480201I7 F - Montants forfaitaires - XXXXXXXXXX||Income Tax Act - Section 6 - Subsection 6(3) - Paragraph 6(3)(d)||amounts paid to workers in wage-discrimination suit that were in excess of reasonable amount for rights’ violations or non-pecuniary damages would be employment income|
|Income Tax Act - 101-110 - Section 110.2 - Subsection 110.2(1) - Qualifying Amount||portion of wage discrimination award that related to loss of salary (based on days’ worked) would be qualifying amount|
|29 November 2011 Roundtable, 2011-0426361C6 F - Price adjustment clause and redemption of shares||Income Tax Act - Section 84 - Subsection 84(3)||deemed dividend arising from preferred share price adjustment clause arises in the year of actual payment|
|General Concepts - Effective Date||deemed dividend through operation of price adjustment clause arises in the adjustment rather than redemption year|
|2013-04-17||27 March 2013 External T.I. 2012-0449661E5 F - Subparagraph 53(2)(c) ITA||Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(c)||effect of ss. 40(3.4) and 112(3.1) on partnership ACB where dividends paid to partnership before share disposition was currently under audit|
|2013-04-10||18 February 2013 Internal T.I. 2013-0477821I7 F - Montants forfaitaires - XXXXXXXXXX||Income Tax Act - Section 3||damages received in wage discrimination suit for pain and suffering were non-taxable|
|2013-03-27||11 March 2013 External T.I. 2012-0432201E5 F - Payment of tax by an institute||Income Tax Act - Section 248 - Subsection 248(3) - Paragraph 248(3)(a)||application of testamentary trust rules to a substitution by testament|
|Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Testamentary Trust - Paragraph (d)||spousal beneficiary of substitution by testament does not taint the resulting deemed testamentary trust by paying the trust taxes|
|21 February 2013 External T.I. 2012-0465711E5 F - Attribution Rules after Divorce||Income Tax Act - Section 74.2 - Subsection 74.2(1)||entire rather than only pro rata portion of a post-divorce capital gain is not subject to attribution|