Over 700 full-text translations of CRA interpretations are available

The table below provides descriptors and links for five Interpretations released in January 2013 (from the 2012 APFF Roundtables), and a Technical Interpretation released last week, all as fully translated by us.

These are additions to our set of 702 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 the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. You are currently in the “open” week for December.

Bundle Date Translated severed letter Summaries under Summary descriptor
2018-11-28 17 September 2018 External T.I. 2018-0751571E5 F - Adjusted cost base of property Income Tax Act - Section 85 - Subsection 85(3) - Paragraph 85(3)(f) operation of s. 85(3)(f) on wind-up of flow-through LP not affected by s. 63.3(3)
Income Tax Act - Section 66.3 - Subsection 66.3(3) s. 66.3(3) does not apply to the cost of shares received on a ss. 85(2) and (3) wind-up of a flow-through share partnership
2013-01-16 5 October 2012 Roundtable, 2012-0453581C6 F - Somme payable - revenus de placements Income Tax Act - 101-110 - Section 104 - Subsection 104(24) acknowledgement of debt under a 25-year note does not satisfy s. 104(24)
5 October 2012 Roundtable, 2012-0453961C6 F - Copropriété indivise (50-50) d'un triplex Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) allocation of lived-in triplex unit to total interest in triplex sold might be made on relative floor area basis if no qualitative variations
5 October 2012 Roundtable, 2012-0451261C6 F - Foreign entity classification Income Tax Act - Section 248 - Subsection 248(1) - Corporation listing of most important criteria for foreign entity classification/separate legal personality not determinative
5 October 2012 Roundtable, 2012-0453181C6 F - Person affiliated with RESP and RDSP Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(g) both a subscriber and beneficiary of RESP can be affiliated with such trust
5 October 2012 Roundtable, 2012-0453141C6 F - RCA, prohibited investment Income Tax Act - Section 207.5 - Subsection 207.5(1) - Advantage whether split-dollar arrangement entails an advantage depends on the particulars