Six further full-text translations of CRA interpretations are available

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

These (and the other full-text translations covering all of the 645 French-language Interpretations released in the last 5 1/2 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
2013-03-20 5 December 2012 Internal T.I. 2012-0451331I7 F - Déductibilité de frais juridiques Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees legal expenses incurred to minimize responsibility under guarantee were not connected to operations which were necessary or incidental to the earning of income
Income Tax Act - Section 60 - Paragraph 60(o) sales tax disputes not covered; expenses start running from audit review
5 July 2012 Internal T.I. 2010-0388551I7 F - Fiducie - retour de sommes Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(6) Foisy test of mental element accepted
Income Tax Act - Section 75 - Subsection 75(2) s. 75(2) does not apply to an estate freeze as the corp does not own its treasury shares issued to the trust
Income Tax Act - 101-110 - Section 105 - Subsection 105(1) income distributed to daughter-in-law who in fact was not a beneficiary includible in her income under s. 105(1) but not deductible by trust under s. 104(6)
Income Tax Act - 101-110 - Section 104 - Subsection 104(13) capital gain distributed by family trust to children and purportedly lent by them to their parents (also beneficiaries) was instead included in the parents’ income under s. 104(13)
31 January 2013 Internal T.I. 2012-0466641I7 F - Réduction du coût en capital d'un bien Income Tax Act - Section 13 - Subsection 13(7.1) reduction for Quebec M&P ITC occurs in year following incurring of the eligible expenses
25 September 2012 Internal T.I. 2011-0409281I7 F - Papier commercial - Obligations XXXXXXXXXX Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Loss v. Loss compensating clients for half their loss was currently deducible, whereas purchasing securities at original cost was its cost
Income Tax Act - Section 54 - Adjusted Cost Base acquiring client securities at the clients' cost rather than their lower FMV was reflected in portfolio manager's cost
2013-03-13 7 January 2013 External T.I. 2012-0460021E5 F - Remboursement de cotisations à un club Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) where “membership in a fitness centre allows the employee to meet … specific conditions [of employment,” the test of “more than 50% … to the employer's advantage” may be met
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(l) denial applies to fitness centre fees, irrespective of benefit to employer
8 February 2013 External T.I. 2012-0464131E5 F - Transfert de propriété Income Tax Act - Section 248 - Subsection 248(1) - Disposition determination of disposition date is assisted by IT-170R