6 more translated CRA interpretations are available [corrected]

15 July 2019 - 11:54pm
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We have published a CRA interpretation released last week and a further 5 translations of CRA interpretations released in November, 2011. Their descriptors and links appear below.

These are additions to our set of 909 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
2019-07-10 4 June 2019 Internal T.I. 2018-0783441I7 F - Sale of land by a resident of Hong Kong Treaties - Income Tax Conventions - Article 13 Canadian land was not Treaty-exempt even where it did not generate income
2011-11-25 7 November 2011 Internal T.I. 2011-0424641I7 F - Right to cut Christmas trees Income Tax Act - Section 13 - Subsection 13(21) - Timber Resource Property right to cut Christmas trees was not a timber resource property
Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(e) Christmas trees are not “timber”
Income Tax Regulations - Schedules - Schedule II - Class 14 right to cut Christmas trees with 10-year term was a Class 14 property
7 October 2011 Roundtable, 2011-0411871C6 F - Employé constitué en société Income Tax Act - Section 125 - Subsection 125(7) - Personal Services Business PSB can have two spouses as incorporated employees
7 October 2011 Roundtable, 2011-0411841C6 F - Succession Income Tax Act - 101-110 - Section 104 - Subsection 104(1) estate could cease when assets converted to cash and liabilities settled
7 October 2011 Roundtable, 2011-0412091C6 F - Late Filed Paragraph 55(5)(f) Designation Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(f) CRA practice to only treat excess of taxable dividend over safe income as subject to s. 55(2)
7 October 2011 Roundtable, 2011-0411891C6 F - Dépenses- EPSP - négociant en vente Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(p) - Sjubparagraph 18(1)(p)(iii) s. 18(1)(p)(iii) deduction limited to commission income
Income Tax Act - Section 8 - Subsection 8(13) home office of a PSP corporation’s employee could qualify