There are now over 1000 of our full-text translations of CRA Interpretations

18 November 2019 - 11:40pm
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We have published a further 6 translations of CRA interpretations released in May 2011. Their descriptors and links appear below.

These are additions to our set of 1,005 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ½ years of releases of Interpretations 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
2011-05-27 18 May 2011 External T.I. 2011-0392441E5 F - Outils - déduction pour amortissement Income Tax Regulations - Schedules - Schedule II - Class 12 - Paragraph (c) small tools were Class 12 assets rather than currently deductible
Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) CCA claim was to be proportionately reduced based on personal use percentage
2011-05-20 11 May 2011 External T.I. 2011-0394231E5 F - Subsections 14(1.01) and 85(1) - Quotas Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1.3) milk quotas could be segregated between those eligible for capital gains deduction and those transferred on rollover basis
Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(a) otherwise-fungible milk quotas could be segregated on the basis of their tax characteristics
9 May 2011 Internal T.I. 2011-0399531I7 F - Computation of safe income Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) non-capital loss that resulted from immediate recognition of expenses but deferral of WIP on construction contracts effected an immediate SIOH reduction
2011-05-13 9 May 2011 External T.I. 2010-0385211E5 F - Entreprise habituelle de prêt d'argent Income Tax Act - Section 15 - Subsection 15(2.3) loans to shareholders at prescribed rate could be part of regular money-lending business
2 May 2011 External T.I. 2011-0392661E5 F - T2 Sched. 3 Reporting of Dividend Paid to a Trust Income Tax Act - 101-110 - Section 104 - Subsection 104(19) dividend paid to trust which then is flowed through to corporate beneficiary is reported as paid to person other than connected corporation
6 May 2011 External T.I. 2011-0399491E5 F - Withholding - stock option benefits Income Tax Act - Section 153 - Subsection 153(1.1) CRA may consider source deductions issue in rulings context