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