8 further translations of CRA French-language interpretations are available

The table below provides descriptors and links for two interpretations that were recently released (while we were engaged in translating the 2018 APFF Roundtables) as well as six interpretation released in February and January 2013, all as fully translated by us.

These are additions to our set of 678 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 5 3/4 years of releases by them These translations are subject to the usual (3 working weeks per month) paywall. You are currently in the "open" week for November.

Bundle Date Translated severed letter Summaries under Summary descriptor
2018-10-17 27 June 2018 External T.I. 2018-0745681E5 F - Wind-up of a partnership Income Tax Act - Section 84 - Subsection 84(3) no s. 84(3) dividend on cancellation of preferred shares of Opco held by partnership on its wind-up into Opco
Income Tax Act - Section 98 - Subsection 98(5) s. 98(5) inapplicable on simultaneous dissolving transfer of partnership interests
Income Tax Act - Section 28 - Subsection 28(1) - Paragraph 28(1)(f) application of s. 28(1)(f) on partnership wind-up
2018-10-10 27 June 2018 External T.I. 2018-0742881E5 F - Royalties under Canada Petroleum Resources Act Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose Canadian Petroleum royalties generally deductible
2013-02-06 24 October 2012 Internal T.I. 2012-0456711I7 F - Inadmissibilité à la déduction pour GC Income Tax Act - Section 248 - Subsection 248(10) concept of a related transaction requires "more than a mere possibility"/retrospective attachment of related transaction
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(7) - Paragraph 110.6(7)(b) potential application of s. 110.6(7)(b) where s. 51(2) applied
Income Tax Act - Section 152 - Subsection 152(4.2) no retroactive adjustment of capital gains exemption where claimed before the normal reasssessment period
15 November 2012 Internal T.I. 2012-0459321I7 F - Biens locatifs - frais de déplacement Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) notwithstanding the s. 18(1)(h) postamable limitation to business income, there is a circumscribed deduction for travel to and from single rental property
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose deductibility of travel expenses to manage rental properties partly turns on whether single or multiple locations
2013-01-30 15 November 2012 External T.I. 2012-0456201E5 F - Frais médicaux - calcul et dépenses non admissibles Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(o) emergency call service through telemonitoring ineligible
Income Tax Regulations - Regulation 5700 - Section 5700 - Paragraph 5700(e) non-custom shoes would not qualify
Income Tax Act - Section 118.2 - Subsection 118.2(1) expenses that were incurred, paid for and receipted within same 12-month period cannot be deferred
5 October 2012 Roundtable, 2012-0453971C6 F - Fiducies successives/disposition 21 ans Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(b) - Subparagraph 104(4)(b)(ii) deemed retroactive date of formation per CCQ of child trusts as residuary testamentary beneficiaries of spousal trusts accelerated s. 104 deemed disposition date
5 October 2012 Roundtable, 2012-0454001C6 F - Travail d'un associé d'une société de personnes Income Tax Act - 101-110 - Section 103 - Subsection 103(1.1) number of employees not necessarily relevant to determining relative partner contribution
7 December 2012 External T.I. 2012-0440411E5 F - Performing services in Canada Income Tax Regulations - Regulation 104 - Subsection 104(2) non-resident programmer who comes to Canada only occasionally and is connected to the Quebec server does not exericse a Canadian employment