We have over 900 full-text translations of CRA Interpretations
8 July 2019 - 11:10pm
Email this ContentWe 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 |