6 more translated CRA interpretations are available

We have published a translation of a CRA interpretation released last week, and a further 6 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 945 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. Next week is the “open” week for September.

Bundle Date Translated severed letter Summaries under Summary descriptor
2019-08-21 17 July 2019 External T.I. 2018-0777951E5 F - Avantage automobile Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) two related joint employers should agree on which of them will T4 an employee for the single s. 6(1)(e) or (k) benefit for the car provided by one of them to him
Income Tax Act - Section 6 - Subsection 6(2) where 2 related employers, only a single benefit under the formula is calculated for each automobile
Income Tax Regulations - Regulation 200 - Subsection 200(3) where 2 related employer, ss. 6(1)(e) or (k) benefit can be reported by either employer
2011-11-04 7 October 2011 Roundtable, 2011-0412191C6 F - Sec. 86 - Reorganisation of the Capital of a Corp. Income Tax Act - Section 51 - Subsection 51(1) s. 51(1) applies where share conversion pursuant only to directors’ resolution
Income Tax Act - Section 86 - Subsection 86(1) reorganization of capital generally requires articles of amendment
7 October 2011 Roundtable, 2011-0408351C6 F - Honoraire d'évaluation d'une police d'assurance Income Tax Act - Section 148 - Subsection 148(1) no deduction from gain for disposition expenses
Income Tax Act - Section 148 - Subsection 148(9) - Adjusted Cost Basis - A valuing the FMV of acquired property not considered to be part of its cost
7 October 2011 Roundtable, 2011-0412211C6 F - Feuillets T4A comptabilité d'exercice Income Tax Regulations - Regulation 200 - Subsection 200(1) CRA will not automatically assess where a T4A appears to show unreported income
7 October 2011 Roundtable, 2011-0412141C6 F - Whether shares of different classes are identical Income Tax Act - Section 47 - Subsection 47(1) otherwise identical shares are different if they have different stated capital
7 October 2011 Roundtable, 2011-0407951C6 F - Options, don d'actions Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d.01) cannot claim both a s. 110(1)(d.01) and s. 110(1)(d.1) deduction
7 October 2011 Roundtable, 2011-0420781C6 F - Transfert de RPA à un REER au décès. Income Tax Act - 101-110 - Section 104 - Subsection 104(27) designation respecting RPP lump sum received by estate respecting disabled minor daughter and transferred to her RRSP
Income Tax Regulations - Regulation 103 - Subsection 103(4) withholding required where RPP administrator pays RPP lump sum directly to RRSP of disabled minor daughter beneficiary of estate
Income Tax Act - Section 60 - Paragraph 60(l) - Subparagraph 60(l)(v) - Clause Subparagraph 60(l)(v)(B.01) s. 60(l) deduction where RPP administrator pays RPP lump sum directly to RRSP of disabled minor daughter beneficiary of estate