6 more translated CRA interpretations are available

14 May 2019 - 12:28am
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We have published translations of 2 CRA interpretations released last week and a further 4 released in March 2012. Their descriptors and links appear below.

These are additions to our set of 855 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.

Bundle Date Translated severed letter Summaries under Summary descriptor
2019-05-08 18 April 2019 External T.I. 2017-0716451E5 F - Deduction in computing income of a trust Income Tax Act - 101-110 - Section 105 - Subsection 105(1) a distribution by a discretionary trust of a taxable capital gain in excess of the trust’s income could be a s. 105(1) benefit
Income Tax Act - 101-110 - Section 104 - Subsection 104(6) - Paragraph 104(6)(b) s. 104(6)(b) deduction cannot exceed net income
25 February 2019 External T.I. 2019-0793911E5 F - Triangular amalgamation and section 135.1 Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(s) - Subparagraph 87(2)(s)(ii) s. 87(2)(s) inapplicable to triangular amalgamation
Income Tax Act - Section 135.1 - Subsection 135.1(2) potential s. 131.1(2) income inclusion on triangular amalgamation
2012-03-09 22 February 2012 External T.I. 2011-0424601E5 F - Scholarships and bursaries paid by a firm Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) potential qualification under s. 56(1)(n) if bursary paid by employer while student not a summer student or permanent employee
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) employer-reimbursed tuition not considered for its training benefit if incurred before employment commenced
23 February 2012 External T.I. 2011-0423461E5 F - Automobiles de collection Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e) vintage automobiles of corporation/distinction between benefit qua employee or shareholder also applies in s. 6(1)(e) context
22 February 2012 External T.I. 2011-0421671E5 F - Loss of retirement income benefit - death Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(f) - Subparagraph 110(1)(f)(ii) deduction for WSIB compensation paid to estate of deceased injured worker
Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(v) inclusion under s. 56(1)(v), offsetting deduction under s. 110(1)(f)(ii), for Ontario WSIB lump sum on death
2012-03-02 21 February 2012 External T.I. 2011-0417471E5 F - Changement d'usage - paragraphe 45(3) Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) s. 45(1)(c) applies where 2nd unit in taxpayer-owned duplex changed from rental to personal use
Income Tax Act - Section 248 - Subsection 248(1) - Property immovable (including a duplex used 2 different ways) is considered a single property unless subdivided
Income Tax Act - Section 45 - Subsection 45(3) s. 45(3) election not available where 2nd unit in taxpayer-owned duplex changed from rental to personal use