6 more translated CRA interpretations are available

28 October 2019 - 11:50pm
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We have published a further 6 translations of CRA interpretations released in July and June, 2011. Their descriptors and links appear below.

These are additions to our set of 987 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 1/3 years of releases of Interpretations by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for November.

Bundle Date Translated severed letter Summaries under Summary descriptor
2011-07-15 4 July 2011 External T.I. 2010-0380071E5 F - Reer au décès Income Tax Act - Section 146 - Subsection 146(1) - Benefit - Paragraph (a) not a taxable “benefit” to non-annuitant if included in annuitant’s income under s. 146(8.8
Income Tax Act - Section 146 - Subsection 146(1.1) factors relevant to determining financial dependence
2011-07-08 24 June 2011 External T.I. 2011-0409741E5 F - Déductions d'impôt sur une bourse de recherche Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(o) assistance received by unenrolled student towards Ph.D. thesis research assistance was a research grant under s. 56(1)(o)
Treaties - Income Tax Conventions - Article 20 assistance received by unenrolled Chinese student towards Ph.D. thesis research assistance was Treaty-exempt
2011-07-01 10 June 2011 Roundtable, 2011-0404641C6 F - Shareholders Agreement and FMV General Concepts - Fair Market Value - Shares examples of clauses reducing the FMV of freeze preferred shares
Income Tax Act - Section 86 - Subsection 86(1) freeze preferred shares must not have a clause that impairs their FMV, e.g., retractability for a NIB term note
2 March 2011 External T.I. 2010-0378071E5 F - CIFM - Quadriporteur Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(i) scooter can qualify as “wheelchair” where it is acquired in lieu of one
22 June 2011 External T.I. 2010-0387391E5 F - Allocations pour véhicule à moteur Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(x) allowance taxable (but s. 8(1)(h.1) deduction) where 2 different rates
Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) employees entitled to s. 8(1)(h.1) deduction where they received an allowance that was taxable under s. 6(1)(b)(x)
2011-06-24 9 June 2011 External T.I. 2011-0393331E5 F - Frais de déplacement - principal lieu d'affaires Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) travel between home office used for back office and 20% of client meetings and other office was personal