7 further translations of CRA interpretations are available

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