6 more translated CRA interpretations are available
28 May 2019 - 12:39am
Email this ContentWe 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 |