6 more translated CRA interpretations are available

6 November 2019 - 11:54pm
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We have published a further 6 translations of CRA interpretations released in June, 2011. Their descriptors and links appear below.

These are additions to our set of 993 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. You are currently in the “open” week for November.

Bundle Date Translated severed letter Summaries under Summary descriptor
2011-06-24 15 June 2011 Internal T.I. 2011-0405501I7 F - Withholding - stock option benefits Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) withholding obligation extends to stock option benefits
Income Tax Act - Section 153 - Subsection 153(1.1) it is up to employer to find a solution for need to withhold from s. 7 benefits
8 October 2010 Roundtable, 2010-0371911C6 F - Biens dévolus au conjoint Income Tax Act - Section 70 - Subsection 70(6) no rollover for bequested shares that had to be sold to satisfy estate debts
10 June 2011 Roundtable, 2011-0404621C6 F - Rectification order in Québec General Concepts - Rectification & Rescission CRA awaiting resolution of AES and Riopel cases
9 June 2011 Internal T.I. 2011-0396721I7 F - Déduction - habitants de régions éloignées Income Tax Act - 101-110 - Section 110.7 - Subsection 110.7(1) regular absences of 8 days on a 43-day cycle did not interrupt “residence” in zone
2011-06-17 9 June 2011 Internal T.I. 2011-0395001I7 F - Co-propriété indivise d'un duplex Income Tax Act - Section 54 - Principal Residence - Paragraph (a) 2 equal co-owners of duplex could each claim the principal residence exemption for “their” unit
General Concepts - Fair Market Value - Land although each 50% co-owner of a duplex has an undivided interest in the whole dwelling, the FMV of her interest relates exclusively to the housing unit occupied by her
General Concepts - Ownership co-ownership interest is in the whole but valuation of the part occupied should reflect rights of exclusive possession
7 June 2011 Internal T.I. 2011-0397921I7 F - Financement inter-sociétés Income Tax Act - Section 15 - Subsection 15(2.1) notwithstanding Gillette, a connected “person” may include a partnership
Income Tax Act - Section 227 - Subsection 227(6.1) refund of withholding tax on repayment of loan
Income Tax Act - Section 80.4 - Subsection 80.4(3) - Paragraph 80.4(3)(b) s. 80.4 would not apply to a s. 15(2) loan if it is not repaid