Six further full-text translations of CRA interpretations are available
27 August 2018 - 11:03pm
Email this ContentThe 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 |