5 more translated CRA interpretations are available

We 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