6 more translated CRA interpretations are available
26 May 2020 - 12:55am
Email this ContentWe have published a translation of a CRA interpretation released last week and a further 5 translations of CRA interpretations released in September and August 2010. Their descriptors and links appear below.
These are additions to our set of 1,180 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. Next week is the “open” week for June.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2020-05-20 | 8 April 2020 External T.I. 2016-0668991E5 F - Death of RRSP or RRIF annuitant | Income Tax Act - Section 146 - Subsection 146(8.9) | discretionary s. 146(8.9) deduction is available even where no timely issuance of T4RSP, but no deduction where annuitant with surviving spouse dies after the maturity of the RRSP |
| Income Tax Act - Section 146.3 - Subsection 146.3(6.2) | s. 146.3(6.2) deduction can be less than the formula amount and does not depend on timely receipt of T4RIF – but applies only when the last annuitant of a RRIF dies | ||
| Income Tax Regulations - Regulation 214 - Subsection 214(4) | T4RSP issued to surviving spouse rather than to deceased where transfer of entire refund of premiums to surviving spouse’s RRSP and RRSP is fully distributed | ||
| Income Tax Regulations - Regulation 215 - Subsection 215(4) | T4RIF issued to surviving spouse rather than to deceased where transfer of entire eligible amount to surviving spouse’s RRSP or RRIF, and RRIF is fully distributed | ||
| Income Tax Regulations - Regulation 205 - Subsection 205(1) | issuer required to issue T4RSP or T4RIF within a reasonable time after notification of death received after February filing date | ||
| 2010-09-10 | 7 June 2010 Internal T.I. 2009-0351031I7 F - Faillite changée en proposition | Income Tax Act - Section 128 - Subsection 128(2) - Paragraph 128(2)(g) - Subparagraph 128(2)(g)(iii) | court approval of consumer proposal and individual’s discharge was not a s. 128(2)(g) unconditional discharge, so that individual thereafter could apply unused tuition tax credits |
| 2010-08-27 | 13 August 2010 External T.I. 2010-0359571E5 F - Crédit d'impôt étranger | Income Tax Act - Section 126 - Subsection 126(1) | foreign withholding tax is borne by the copyright holder rather than the Cdn. selling agent |
| 2010-08-13 | 6 August 2010 External T.I. 2010-0364091E5 F - Utilisation d'un véhicule fourni par l'employeur | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(e) | benefit even if the vehicle is made available for responding quickly to an emergency |
| 23 June 2010 Internal T.I. 2010-0368161I7 F - 84.1 | Income Tax Act - Section 84.1 - Subsection 84.1(2) - Paragraph 84.1(2)(b) | s. 84.1(2)(b) inapplicable to individual’s transfer of ½ of Opco to Holdco (owned by 3 unrelated individuals) for note and non-voting pref | |
| Income Tax Act - Section 84.1 - Subsection 84.1(2.2) - Paragraph 84.1(2.2)(b) | s. 84.1(2.2)(b) group can include a non-voting shareholder | ||
| 4 August 2010 External T.I. 2009-0330501E5 F - Superficial loss | Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(b) - Subparagraph 251.1(1)(b)(ii) | X (holding the Opco non-voting shares), and a discretionary trust (holding the Opco voting shares) of which X was a beneficiary, were an affiliated group |