Our translations of CRA interpretations go back 10 years
We have published a further 5 translations of CRA interpretations released in July and June 2010. Their descriptors and links appear below.
These are additions to our set of 1,198 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 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|
|2010-07-02||17 May 2010 External T.I. 2009-0346011E5 F - Immeuble - Convention Canada - Portugal||Treaties - Income Tax Conventions - Article 25||no discrimination in Canada taxing a Canadian resident on a Portuguese real estate gain exempted from Portuguese tax|
|Income Tax Act - Section 54 - Principal Residence - Paragraph (a)||Portuguese home of Canadian resident could qualify for the principal residence exemption|
|21 May 2010 External T.I. 2009-0352221E5 F - Bien de remplacement- résidence principale||Income Tax Act - Section 44 - Subsection 44(5) - Paragraph 44(5)(a.1)||replacement property rules re involuntary disposition of secondary residence in country could apply to replacement property in city|
|14 May 2010 External T.I. 2009-0323151E5 F - Cross Border Stock Option||Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(b) - Subparagraph 128.1(1)(b)(iv)||individual fully taxable on s. 7 benefit without carve-out for portion that had accrued prior to immigration to Canada|
|23 June 2010 External T.I. 2010-0365581E5 F - Règles d'attribution de l'article 74.2||Income Tax Act - Section 74.5 - Subsection 74.5(1) - Paragraph 74.5(1)(c)||s. 74.2(1) inapplicable to transfer at FMV of property to a discretionary family trust, with capital gain on property subsequently distributed to spouse of transferor|
|Income Tax Act - Section 75 - Subsection 75(2)||s. 75(2)(a)(i) is satisfied where a person transferring to a trust holds a capital interest in that trust|
|2010-06-25||16 June 2010 External T.I. 2009-0344861E5 F - Actifs de la Catégorie 16||Income Tax Regulations - Schedules - Schedule II - Class 16 - Paragraph (e)||pick-up trucks leased out on short-term basis but also used as described in (e)(ii) of automobile are in Class 16 - otherwise, Class 10|