6 further translations of CRA interpretations are available

28 January 2019 - 11:42pm
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We have published a further 6 translations of interpretations released in October 2012. Their descriptors and links appear below.

These are additions to our set of 765 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ¼ years of releases by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for February.

Bundle Date Translated severed letter Summaries under Summary descriptor
2012-10-31 10 September 2012 External T.I. 2012-0446921E5 F - Avantage pour automobile Income Tax Act - Section 6 - Subsection 6(2) transfer to related corp stepped down cost for standby charge purposes to FMV
Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(e.4) car acquired at cost equal to FMV for standby charge purpose notwithstanding s. 85(1) election
22 October 2012 Internal T.I. 2012-0459681I7 F - Hiring Credit for Small Business and CCE deduction Income Tax Act - Section 63 - Subsection 63(1) - Paragraph 63(1)(d) HCSB credit reduces babysitting expense re EI premiums
20 September 2012 External T.I. 2011-0430811E5 F - Attribution à un établissement stable Income Tax Regulations - Regulation 402 - Subsection 402(4) - Paragraph 402(4)(c) - Subparagraph 402(4)(c)(ii) application of Reg. 404(4)(c)(ii) to ore processed in two provinces
Income Tax Regulations - Regulation 402 - Subsection 402(4) - Paragraph 402(4)(b) as Reg. 404(4)(c)(ii) prevailed over Reg. 404(4)(b) re ore processed in two provinces, its application would not be affected by the negotiation of the export sales by personnel in the 2nd province
18 September 2012 External T.I. 2012-0442581E5 F - Fiducie au profit d'un athlète amateur Income Tax Act - Section 143.1 - Subsection 143.1(2) amounts distributed from athlete trust were business income
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose expenses of athlete with athlete trust
Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit tests for source of business income for amateur athlete
18 September 2012 External T.I. 2011-0423941E5 F - Entreprise de prestation de services personnels Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(p) - Subparagraph 18(1)(p)(ii) cost of benefit to corp generally equals allowance amount and can be the cost of a non-s. 6 benefit – however no benefit if cell phone used primarily in course of employment
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) no taxable benefit if cell phone used primarily in employment
2012-10-17 2 October 2012 External T.I. 2012-0446671E5 F - Subsection 78(4) Income Tax Act - Section 78 - Subsection 78(4) s. 78(4) inapplicable where payment made on 180th day