Our translations of CRA interpretations go back 9 years
25 February 2020 - 12:07am
Email this ContentWe have published a further 5 translations of CRA interpretations released in February, 2011. Their descriptors and links appear below.
These are additions to our set of 1,094 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 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 March.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2011-02-25 | 8 October 2010 Roundtable, 2010-0373161C6 F - Paragraphs 256(3) and 256(6) ITA | Income Tax Act - Section 256 - Subsection 256(6) | application could prevent acquisition of control or preclude loss of CCPC status |
| 8 October 2010 Roundtable, 2010-0373191C6 F - Computation of safe income | Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | where interest in partnership holding Subco with safe income is rolled into Holdco for prefs, dividends from Subco do not change consolidated SIOH of prefs – or increase commons’ SIOH | |
| 2011-02-18 | 8 October 2010 Roundtable, 2010-0373131C6 F - Présomption d'action concertée | Income Tax Act - Section 251.2 - Subsection 251.2(2) - Paragraph 251.2(2)(a) | Q of fact re whether 3 or more CCPC shareholders form a group |
| 9 December 2010 Internal T.I. 2010-0371741I7 F - Automobiles mises à la disposition des employés | Income Tax Act - Section 248 - Subsection 248(1) - Automobile | qualification as automobiles turns on design, not use | |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e) | employer-provided automobile to attend occasional off-site meetings did not generate a benefit | ||
| 24 January 2011 Internal T.I. 2010-0389251I7 F - Farm-out agreement and warrants | Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (j) | CEE to be incurred under simple farmout reduced by an allocation to warrants issued by farmee | |
| Income Tax Act - Section 15 - Subsection 15(1) | valuation of “free” warrants issued as part of a simple farmout agreement determined based on what would be a s. 15(1) benefit | ||
| General Concepts - Fair Market Value - Options | amount allocated out of consideration to “free” warrants based on the greater of their trading and in-the-money value | ||
| Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | application of farmout policy to situation where free warrants issued along with incurring of CEE |