6 more translated CRA interpretations are available

20 August 2019 - 1:06am
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We have published a translation of a CRA interpretation released last week, and a further 5 translations of CRA interpretations released in November, 2011 (all of them, from the October 2011 APFF Roundtables). Their descriptors and links appear below.

These are additions to our set of 939 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 7 3/4 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
2019-08-14 10 June 2019 Internal T.I. 2019-0796221I7 F - Qualification d’un véhicule à titre de « voiture de tourisme » Income Tax Act - Section 248 - Subsection 248(1) - Automobile a passenger vehicle ceases to qualify as such when it commences to be used as a taxi given the s. 13(7)(b) deemed acquisition
Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(b) s. 13(7)(b) applies when passenger vehicle converted to taxi use
2011-11-04 7 October 2011 Roundtable, 2011-0411811C6 F - Règlement 1101(5b.1) Income Tax Regulations - Regulation 1101 - Subsection 1101(5b.1) Reg. 1101(5b.1) election can be made in partnership T5013, or by a partner
7 October 2011 Roundtable, 2011-0411851C6 F - Fiducie de protection d'actifs Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Testamentary Trust - Paragraph (b) distribution of property from asset protection trust directly, rather than via estate, to testamentary trust would taint it
General Concepts - Effective Date trust deed clause deeming trust property to be distributed immediately prior to death would not be recognized as taking effect at that time
7 October 2011 Roundtable, 2011-0406551C6 F - Régime coll. d'ass. maladie et les accidents Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) PHSP can include spouses and dependent related persons
Income Tax Act - Section 144.1 - Subsection 144.1(1) - Designated Employee Benefit benefit from a group sickness or accident insurance plan may be paid from a Life and Health Trust to the employee, spouse or dependent child
7 October 2011 Roundtable, 2011-0412061C6 F - Financing Expenses Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) - Subparagraph 20(1)(e)(i) no s. 20(1)(e) deduction if only capital property that is not a source of income
Income Tax Act - Section 20 - Subsection 20(1) property that is source only of capital gains cannot support a s. 20 deduction