6 further translations of CRA French-language interpretations are available

10 December 2018 - 11:30pm
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The table below provides descriptors and links for six Interpretations released in January 2013 (including two 2012 APFF Roundtable items), all as fully translated by us.

These are additions to our set of 708 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.

Bundle Date Translated severed letter Summaries under Summary descriptor
2013-01-16 5 October 2012 Roundtable, 2012-0454141C6 F - Déductibilité des frais afférents à un véhicule Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) s. 6(1)(b) inclusion and s. 8(1)(h.1) deduction where allowance received for daily travel only in excess of 40 kilometres
5 October 2012 Roundtable, 2012-0451251C6 F - Excess of foreign tax withheld at source Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax foreign withholdings on American depositary receipts in excess of Treaty-limited rate does not qualify as an income tax
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose tax withheld in excess of Treaty-rate is not deductible as an expense
15 October 2012 Internal T.I. 2012-0452161I7 F - Frais de garde, revenu gagné, RQAP Income Tax Act - Section 63 - Subsection 63(3) - Earned Income Quebec Parental Insurance Plan (QPIP) benefits not included in earned income
2013-01-09 16 October 2012 External T.I. 2011-0425271E5 F - Small CCPC Income Tax Regulations - Regulation 5301 - Subsection 5301(4) - Paragraph 5301(4)(a) Amalco’s instalments based on tax payable of predecessors
Income Tax Regulations - Regulation 5301 - Subsection 5301(6) - Paragraph 5301(6)(a) flow-through of attributes of wound-up sub
Income Tax Regulations - Regulation 5301 - Subsection 5301(8) - Paragraph 5301(8)(a) 1st instalment base of transferor taken into account by transferee
Income Tax Act - Section 157 - Subsection 157(1.2) - Paragraph 157(1.2)(a) carryback of losses can produce small CCPC ("SCCPC") status (quarterly instalments) but not reduce instalment base
5 November 2012 External T.I. 2012-0458801E5 F - Frais de déménagement Income Tax Act - Section 248 - Subsection 248(1) - Eligible Relocation move can relate to an existing workplace if there is a causal link
5 November 2012 External T.I. 2012-0445241E5 F - 54 et 40(2)b) Income Tax Act - Section 54 - Principal Residence whether a duplex is a single housing unit turns on the degree of independence v. integration of the two units