Six further full-text translations of CRA interpretations are available
10 September 2018 - 11:26pm
Email this ContentThe 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 |