We have over 900 full-text translations of CRA Interpretations
We have published a further 6 translations of CRA interpretations released in December and November, 2011. Their descriptors and links appear below.
These are additions to our set of 903 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 7 2/3 years of releases by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall.
|Bundle Date||Translated severed letter||Summaries under||Summary descriptor|
|2011-12-02||24 November 2011 External T.I. 2011-0416791E5 F - Shareholder Benefit||Income Tax Act - Section 15 - Subsection 15(1)||payment by Opco of whole life insurance premiums on policy of which it is beneficiary, but sole shareholder is holder, generates s. 15 benefit – but not policy loan advance|
|21 November 2011 External T.I. 2011-0416881E5 F - Late-filed designation - paragraph 88(1)(d)||Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d)||provided year of property disposition not-statute-barred, CRA generally will accept a late designation allocating s.88(1)(d) excess pro rata amongst the eligible properties|
|22 November 2011 External T.I. 2011-0420451E5 F - Canadian resource property||Income Tax Act - Section 66.2 - Subsection 66.2(5) - Canadian development expense - Paragraph (e)||farm-in policy inapplicable where an option that might not be exercised: CDE addition as cash and exploration expenditures made|
|31 October 2011 External T.I. 2011-0422981E5 F - Whether property is eligible for a bump||Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c) - Subparagraph 88(1)(c)(v)||properties not bumpable as the subsidiary control was deemed by s. 88(1)(d.2) to be acquired at the same time as it acquired the properties|
|Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(c) - Subparagraph 88(1)(c)(vi)||bump unavailable given previous non-arm's length acquisition|
|Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d.2)||properties not bumpable as not owned at subsidiary's formation by related person|
|2011-11-25||7 October 2011 Roundtable, 2011-0411911C6 F - Exploitation entreprise par SP||Income Tax Act - Section 96||Quebec partnership need not carry on business|
|Income Tax Regulations - Regulation 2601 - Subsection 2601(1)||property income of partnership is taxable only to partner (as to its share) in its province of residence|
|7 October 2011 Roundtable, 2011-0411831C6 F - Définition du mot mois||Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (b)||individual required to have held shares for 24 months plus one day to and including day of the determination time|
|Statutory Interpretation - Interpretation Act - Section 35||24-month period preceding time on Date X interpreted as extending back 24 months from the day before Date X|