6 further full-text translations of CRA interpretations are available

5 March 2019 - 12:22am
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We have published a further 6 translations of interpretations released in June 2012. Their descriptors and links appear below.

These are additions to our set of 795 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ¾ 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 March.

Bundle Date Translated severed letter Summaries under Summary descriptor
2012-06-22 24 April 2012 Internal T.I. 2011-0400671I7 F - Honoraires professionnels Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs fees incurred by individual before intention to form a corp did not qualify as pre-incorporation expenses
Income Tax Act - Section 15 - Subsection 15(1) meaning of “benefit”
Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) tax planning fees paid to joint counsel qualified as a disposition expense
2012-06-15 30 May 2012 Internal T.I. 2012-0434471I7 F - Remise de prix non monétaires aux employés Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) distinction between non-cash award for overall contribution to workplace and performance recognition
17 May 2012 Internal T.I. 2012-0437001I7 F - Price Adjustment Clause General Concepts - Effective Date per Gurberg, a PAC has retroactive effect
Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(e.2) no need to file amended s. 85(1) election where PAC engaged
14 May 2012 Internal T.I. 2010-0367831I7 F - Régime de pension étranger. France Income Tax Act - Section 5 - Subsection 5(1) contributions paid by employer to voluntary French pension funds for expatriates were constructively received by employee member
Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement since employer acted as employee agent in making pension contributions, no RCA, EBP or SDA
23 May 2012 Internal T.I. 2011-0418071I7 F - Remise de dettes, PAC Income Tax Act - Section 80 - Subsection 80(3) - Paragraph 80(3)(a) debt settlement results in immediate application of forgiven amount to reduce NCL at that time
Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss - D.2 debt settlement results in immediate application of forgiven amount to reduce NCL at that time
2012-06-08 7 October 2011 APFF Roundtable, 2010-0371941C6 F - Application de l'article 80 - fusion/liquidation Income Tax Act - Section 80 - Subsection 80(1) - Relevant loss balance NCL of acquired subsidiary preserved for debt forgiveness purposes on amalgamation but lost (if business ceased) on wind-up
Income Tax Act - Section 88 - Subsection 88(1.1) - Paragraph 88(1.1)(e) fiction in s. 80(13) is insufficient to preserve non-capital losses of a subsidiary from a business that ceased following an AOC where subsidiary wound-up and parent has forgiven amount