6 more translated CRA interpretations are available

We have published a translation of a CRA interpretation released last week and a further 5 translations of CRA interpretations released in April 2012. Their descriptors and links appear below.

These are additions to our set of 819 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 7 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 April.

Bundle Date Translated severed letter Summaries under Summary descriptor
2019-03-27 29 January 2019 External T.I. 2018-0780481E5 F - Tenir un établissement domestique autonome Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) - Subpargraph 6(6)(a)(i) can qualify as self-contained domestic establishment if no ownership but expense responsibility
Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) “self-contained domestic establishment” entails expense responsibilty
2012-04-20 29 March 2012 Internal T.I. 2011-0430871I7 F - Participation à une étude de recherche clinique Income Tax Act - Section 5 - Subsection 5(1) "volunteers" for drug clinical trials earned business rather than employment income
Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit compensation received by participants in clinical drug studies were business income even where they had a personal interest in the study
2012-04-13 29 March 2012 External T.I. 2011-0427821E5 F - Biens agricoles admissibles Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Interest in a Family Farm or Fishing Partnership potential qualification where farm property of partnership is leased to farming corp. with same family owners
Income Tax Act - Section 30 s. 30 expenses can be claimed by farming lessee or carried forward
1 March 2012 Internal T.I. 2012-0437901I7 F - Timing of the adjustments pursuant to 111(5) Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a) acquisition of control of target does not reduce its NCLs at that time – streaming rules apply prospectively
26 March 2012 External T.I. 2012-0440441E5 F - Déduction accordée aux petites entreprises Income Tax Act - Section 125 - Subsection 125(1) trite SBD overview
17 June 2011 Internal T.I. 2011-0394471I7 F - Associated Corporations - 256 Income Tax Act - Section 256 - Subsection 256(2) s. 256(2) does not multiply the SBD but protects it where particular corporations otherwise are eligible
Income Tax Act - Section 256 - Subsection 256(2.1) list of 5 “useful” factors in determining s. 256(2.1) application
Income Tax Act - Section 256 - Subsection 256(5.1) Transport M.L. Couture cited as an example