6 further translations of CRA interpretations are available

14 January 2019 - 11:36pm
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We have published another 6 translations of CRA interpretations – one of which was released last week and the others in December and November 2012. Their descriptors and links appear below.

These are additions to our set of 753 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.

Bundle Date Translated severed letter Summaries under Summary descriptor
2019-01-09 19 July 2018 External T.I. 2014-0551941E5 F - Déplacement effectué par un employé Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) travel allowances of employees at accounting firms for travel on their audit engagements might be taxable
2012-12-05 5 October 2012 APFF Roundtable Q. 13, 2012-0454181C6 F - Discretionary Dividend Shares Income Tax Act - Section 245 - Subsection 245(4) general policy against conferring a benefit on a corporation
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(7) - Paragraph 110.6(7)(b) acquisition by Holdco of discretionary dividend shares of Opco at undervalue could engage s. 110.6(7) application to Opco commons
Income Tax Act - Section 15 - Subsection 15(1) discretionary dividend shares issued for nominal consideration
2012-11-28 27 August 2012 Internal T.I. 2012-0435571I7 F - Opposition à une cotisation Income Tax Act - Section 165 - Subsection 165(1) Act does not limit the reasons for an objection (taxpayer can change mind up to objection time)
22 October 2012 External T.I. 2012-0432241E5 F - Impôt des enfants mineurs - gain en capital Income Tax Act - Section 120.4 - Subsection 120.4(4) purported dirty s. 85(1) capital gains crystallization by minor child instead generates dividend
2012-11-14 22 October 2012 External T.I. 2012-0452491E5 F - Repas fournis dans le cadre d'une formation Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(a) Pink Elephant followed/potential exception for training business where it breaks out meals on its invoices
Income Tax Act - Section 67.1 - Subsection 67.1(1) trainees required to break out meal portion of their invoices even if not separately identified
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Know-How and Training training expenses deductible (subject to s. 67.1(1)) provided that no new skill or qualification is acquired
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) deductibility of meal portion of training charges may be denied under s. 18(1)(h)
10 October 2012 External T.I. 2012-0451751E5 F - Statut fiscal des artistes /présomption Income Tax Act - Section 5 - Subsection 5(1) status as an employee not affected by presumption in Quebec Status of Artists Act that an independent contractor