5 more translated CRA interpretations are available
12 May 2020 - 12:11am
Email this ContentWe have published a further 5 translations of CRA interpretations released in September, 2010. Their descriptors and links appear below.
These are additions to our set of 1,169 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 ¾ 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 |
|---|---|---|---|
| 2010-09-17 | 25 August 2010 External T.I. 2010-0374231E5 F - Safe income allocation | Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | safe income required to be allocated to prefs and new common shares received on a s. 51 exchange even where the redemption amount of the prefs matched the amount of such safe income |
| General Concepts - Fair Market Value - Shares | Compliance Programs Branch now providing advance guidance on valuation methodology | ||
| 2010-09-10 | 17 August 2010 External T.I. 2010-0367371E5 F - Fin d'un usufruit - résidence principale | Income Tax Act - Section 248 - Subsection 248(3) | dissolution of s. 248(3) trust when the usufructuaries renounced their right of usufruct |
| Income Tax Act - Section 54 - Principal Residence - Paragraph (a.1) | usufructuary parents were specified beneficiaries based on their inhabiting the housing unit | ||
| Income Tax Act - 101-110 - Section 107 - Subsection 107(2.01) | deemed s. 248(3) trust that dissolved when the usufructuary parents renounced their, makes a s. 107(2.01) or (2.001) to apply principal residence exemption to dissolution gain | ||
| 12 August 2010 External T.I. 2010-0360171E5 F - Déclaration T-1135 et biens étrangers | Income Tax Act - Section 233.2 - Subsection 233.2(1) - Exempt Trust | exempt foreign trust definition contains strict conditions | |
| Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Property - Paragraph (n) | Swiss vested benefits account was not exempted | ||
| 24 August 2010 External T.I. 2010-0354791E5 F - Commission d'un non-résident - 105(1) RIR | Income Tax Regulations - Regulation 105 - Subsection 105(1) | fee for services performed wholly in UK re sale of Canadian real estate not subject to withholding | |
| 19 August 2010 External T.I. 2009-0344111E5 F - Résidence Société Capital-Risque - Conv Can-France | Treaties - Income Tax Conventions - Article 4 | French venture capital corporation is resident in France (“liable to tax”) notwithstanding that it has elected to be exempt on its portfolio gains |