6 more translated CRA interpretations are available

We have published translations of a CRA interpretation released last week, an interpretation released in July 2012 (which a few months ago we missed translating in its proper sequence) and a further 4 CRA interpretations released in February, 2012. Their descriptors and links appear below.

These are additions to our set of 867 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 7 1/3 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 June.

Bundle Date Translated severed letter Summaries under Summary descriptor
2019-05-22 26 May 2016 External T.I. 2014-0527251E5 F - Interest Deductibility Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest was deductible on a note indirectly issued to satisfy a dividend
2012-07-27 3 July 2012 External T.I. 2012-0448651E5 F - Allocation of Safe Income Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) apportionment of safe income amongst three classes of discretionary common shares took into account the entitlement of the first class under the USA to a preferential dividend
2012-02-17 8 February 2012 Internal T.I. 2011-0431581I7 F - Sous-alinéa 6(1)a)(vi) proposé General Concepts - Effective Date taxpayers can file based on proposed legislation and wait until announcement that it will not be implemented
Income Tax Act - Section 220 - Subsection 220(3.1) no penalties if taxpayer promptly refiles after announcement that favourable amendment will not proceed
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(vi) “studies” are at all levels and bursaries and tuition reimbursements potentially are included
2012-02-10 27 January 2012 Internal T.I. 2011-0428831I7 F - Crédit d'impôt pour frais médicaux Income Tax Act - Section 118.2 - Subsection 118.2(3) - Paragraph 118.2(3)(b) taxpayer could claim credit for years where he was no longer entitled to claim repaid Quebec drug benefit against private plan due to being out of time
Income Tax Act - Section 152 - Subsection 152(4.2) application under s. 152(4.2) for drug claim deductions that later emerged
12 January 2012 External T.I. 2011-0421791E5 F - Usufruit de terres boisées acquises avant 1987 Income Tax Act - Section 248 - Subsection 248(3) - Paragraph 248(3)(a) gift of bare ownership resulted in deemed disposition to deemed s. 248(3)(a) personal trust
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1.3) - Paragraph 110.6(1.3)(c) property acquired before 18 June 1987 will qualify if s. 110.6(1.3)(c) (i) or (ii) satisfied
27 January 2012 External T.I. 2011-0421551E5 F - Pompiers volontaires Income Tax Act - Section 3 modest amounts received by volunteers are not taxable
Income Tax Act - Section 118.06 - Subsection 118.06(1) “volunteer” firefighters are not true volunteers