6 more translated CRA interpretations are available
4 June 2019 - 12:46am
Email this ContentWe 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 |