Six further full-text translations of CRA interpretations are available

25 September 2018 - 12:40am
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The table below provides descriptors and links for six Interpretations released in February 2013, as fully translated by us.

These (and the other full-text translations covering all of the 657 French-language Interpretations released in the last 5 2/3 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 October.

Bundle Date Translated severed letter Summaries under Summary descriptor
2013-02-20 15 January 2013 Internal T.I. 2012-0459581I7 F - 163(2) Penalty - CCTB and GSTC Income Tax Act - Section 163 - Subsection 163(2) - Paragraph 163(2)(c) penalty applied to both spouses even though only one received an overpayment of the CCTB and GSTC
14 January 2013 External T.I. 2012-0443561E5 F - Part XIII re: royalties paid for tv program Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(i) payments based on TV production costs came within s. 212(1)(d)(i)
Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(vi) copyright exception applicable to use of TV format in producing a Canadianized TV production
Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) payments based on production costs of a television program were a royalty
5 December 2012 Internal T.I. 2012-0439301I7 F - Reassessment beyond the normal reassessment period Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(b) - Subparagraph 152(4)(b)(iii) s. 17 assessment of loan made by Canco to non-resident LP was re a transaction with the non-resident partners for s. 152(4)(a)(iii) purposes
Income Tax Act - Section 96 partnership lacks power to contract debts
6 December 2012 External T.I. 2012-0463431E5 F - Application of subparagraph 40(2)(g)(ii) Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) loss on non-interest-bearing loan to sister did not come within IT-239R2, para. 6
2013-02-06 15 November 2012 External T.I. 2012-0461291E5 F - Frais judiciaires pour clarifier une servitude Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) costs of preventing an expanded easement on land were not a disposition expense
Income Tax Act - Section 54 - Adjusted Cost Base no comment on whether legal costs to avoid expanded easement were ACB addition
20 November 2012 External T.I. 2012-0463191E5 F - Acquisition - personne ayant lien de dépendance Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) increased recapture as a result of previous application of s. 13(7)(e)(i) to acquisition of building from son