We have released another 7 translations of CRA interpretations released in December 2012 including 5 from the 2012 APFF Roundtables.
These are additions to our set of 747 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 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 January.
| Bundle Date |
Translated severed letter |
Summaries under |
Summary descriptor |
| 2012-12-24 |
5 October 2012 Roundtable, 2012-0453161C6 F - RRIF, prohibited investment, minimum amount |
Income Tax Act - Section 146.3 - Subsection 146.3(1) - Retirement Income Fund |
payout of transitional prohibited investment benefit may be taken into account as satisfying the minimum amount |
| 5 October 2012 APFF Roundtable, 2012-0454171C6 F - Taxable Pref. Shares and Short-Term Pref. Shares |
Income Tax Act - Section 248 - Subsection 248(1) - Taxable Preferred Share - Paragraph (f) |
para. (f) tests applied at time of payment and receipt of dividend |
| 5 October 2012 APFF Roundtable, 2012-0453891C6 F - Price Adjustment Clause |
General Concepts - Effective Date |
operation of freeze price adjustment clause depends on share actually being adjusted and can apply for s. 75(2) purposes |
| Income Tax Act - Section 75 - Subsection 75(2) |
price adjustment clause that is implemented potentially can prevent s. 75(2) application to estate freeze |
| 2012-12-12 |
20 November 2012 External T.I. 2012-0440031E5 F - Quebec Tax Credit for Production of Performances |
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv) |
Québec Credit for the Production of Performances includible under ss. 12(1)(x)(iii) and (iv) rather than s. 9 |
| 2012-12-05 |
7 November 2012 External T.I. 2012-0437821E5 F - Registered Plan - Advantage |
Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) |
advantage from swap transaction includes 100% of resulting value increase, income on transferred property and income on income |
| 5 October 2012 APFF Roundtable, 2012-0454091C6 F - GRIP and deemed dividend pursuant to 84.1(1)(b) |
Income Tax Act - Section 84.1 - Subsection 84.1(1) - Paragraph 84.1(1)(b) |
unnecessary in s. 89(14) for s. 84.1 to have deemed dividend to be paid on shares |
| Income Tax Act - Section 89 - Subsection 89(14) |
s. 84.1 deemed dividend paid to an individual could be an eligible dividend notwithstanding him not being a shareholder of the payer |
| 5 October 2012 APFF Roundtable, 2012-0454111C6 F - Power of attorney and acquisition of control |
Income Tax Act - Section 251.2 |
power of attorney in event of capacity is an external docuement which, when judically approved, does not effect a change of control |
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