6 more translated CRA interpretations are available
We have published translations of a CRA interpretation released last week, and a further 5 CRA interpretations released in January, 2012. Their descriptors and links appear below.
These are additions to our set of 873 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. You are currently in the “open” week for June.
|Bundle Date||Translated severed letter||Summaries under||Summary descriptor|
|2019-05-29||15 September 2017 External T.I. 2017-0696821E5 F - Amalgamation||Income Tax Act - Section 87 - Subsection 87(1) - Paragraph 87(1)(a)||receipt of cash on amalgamation did not preclude qualification under s. 87(1) [per Envision, 2013 SCC 48?]|
|Income Tax Act - Section 87 - Subsection 87(4)||receipt of cash on amalgamation precluded rollover|
|2012-01-27||4 January 2012 External T.I. 2011-0417371E5 F - Frais de garde d'enfants||Income Tax Act - Section 63 - Subsection 63(3) - Child Care Expense - Paragraph (b) - Subparagraph (b)(i)||child care corporation can render qualifying child care services to the child of its sole shareholder|
|4 January 2012 External T.I. 2011-0418291E5 F - Transfert entre conjoints||Income Tax Act - Section 74.2 - Subsection 74.2(1) - Paragraph 74.2(1)(a)||s. 74.2 attribution cease on divorce/s. 74.5(3)(b) election available after marriage breakdown|
|9 January 2012 External T.I. 2011-0427461E5 F - Attribution Rules and Suspended Loss Rules||Income Tax Act - Section 74.2 - Subsection 74.2(1)||stop-loss rule in s, 40(3.6) trumped s. 74.2(1) so that denied capital loss was added to transferee spouse’s common share ACB|
|Income Tax Act - Section 40 - Subsection 40(3.6)||stop-loss rule in s, 40(3.6) gave ACB addition to commons shares of transferee spouse who redeemed preferred shares gifted to him by spouse|
|19 January 2012 External T.I. 2011-0414341E5 F - Déf revenu brut location Partie XIII||Income Tax Act - Section 216 - Subsection 216(4)||election permits withholding only on net amount remitted by agent-manager to NR owner|
|Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d)||agent-manager required to withhold on gross rent rather than net rent remitted absent s. 216(4) election|
|7 October 2011 APFF Roundtable Q. 23, 2011-0412111C6 F - Validity of Price Adjustment Clause||General Concepts - Effective Date||price adjustment clause does not require filing amended election|
|Income Tax Act - Section 85 - Subsection 85(7.1)||validity of price adjustment clause does not depend on filing an amended election|