Our translations of CRA interpretations go back 9 years

We 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