6 more translated CRA interpretations are available

9 December 2019 - 11:43pm
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We have published a further 6 translations of CRA interpretations released in April 2011, including 3 items from the 2010 APFF Roundtable. Their descriptors and links appear below.

These are additions to our set of 1,023 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 2/3 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
2011-04-08 8 October 2010 Roundtable, 2010-0373661C6 F - Calcul de surplus et NIIF Income Tax Regulations - Regulation 5907 - Subsection 5907(2.1) IFRS statements can only be used if prepared in accordance with local laws
8 October 2010 Roundtable, 2010-0373651C6 F - Monnaie fonctionnelle - PCGR et NIIF Income Tax Act - Section 261 - Subsection 261(1) - Functional Currency 3 differences between GAAP and s. 261 determination of functional currency
8 October 2010 Roundtable, 2010-0373531C6 F - Qualification de bien exclu - 95(1) Income Tax Act - Section 95 - Subsection 95(1) - Excluded Property - Paragraph (a) factors relevant to degree of use of licence in active business
2011-04-01 21 March 2011 External T.I. 2010-0375341E5 F - Associé déterminé Income Tax Act - Section 248 - Subsection 248(1) - Specified Member an upper-tier partnership, and potentially a corporate partner, may be actively involved in the partnership
23 March 2011 External T.I. 2010-0382351E5 F - Bourses d'études ou subventions de recherche Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(o) research was conducted in course of doctoral studies, so that expenses thereof non-deductible
12 January 2011 External T.I. 2010-0388821E5 F - Discretionary dividend Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) SIOH where two discretionary-dividend classes potentially allocable fully to class with 100% winding-up participation
Income Tax Act - Section 186 - Subsection 186(2) Opco with voting shares held by individual and prefs held by his Holdco was connected to Holdco