We have translated 5 more CRA Interpretations

6 July 2020 - 11:38pm
Email this ContentEmail this Content

We have published a further 5 translations of CRA interpretations released in June and May, 2010. Their descriptors and links appear below.

These are additions to our set of 1,214 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. You are currently in the “open” week for July.

Bundle Date Translated severed letter Summaries under Summary descriptor
2010-06-04 19 May 2010 External T.I. 2010-0364761E5 F - Beneficiary not taxed on Part XII.4 tax credit Income Tax Act - Section 127.41 - Subsection 127.41(1) Pt XII.4 tax credit is received by the taxpayer respecting Pt XII.4 tax paid by the QET
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv) s. 12(1)(x) inapplicable to s. 127.41 credit
19 May 2010 External T.I. 2010-0364131E5 F - Issuance - Discretionary shares Income Tax Act - Section 15 - Subsection 15(1) subscription for discretionary shares of Opco might represent a s. 15(1) benefit conferred by Opco on subscriber, or engage s. 69(1)(b) where this is benefit conferred by existing shareholder
Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) Kieboom/s. 69(1)(b) rather than s. 15(1) where benefit conferred by shareholder rather than corporation
Income Tax Act - Section 74.1 - Subsection 74.1(1) application of Kiebom to consider interest in corp to have been transferred to spouse could engage s. 74.1(1)
27 May 2010 External T.I. 2010-0359491E5 F - Programme Agri-investissement Income Tax Act - Section 12 - Subsection 12(10.2) withdrawal from second AgriInvest Fund is property income except for s. 125 purposes
20 May 2010 External T.I. 2009-0352801E5 F - Caractère raisonnable - honoraires de gestion Income Tax Act - Section 67 factors reviewed in considering reasonableness of management fees
2010-05-28 19 May 2010 External T.I. 2010-0357071E5 F - Crédit d'impôt pour l'achat d'une 1e habitation Income Tax Act - Section 118.05 - Subsection 118.05(1) - Qualifying Home - Paragraph (a) - Subparagraph (a)(iii) ownership by common-law partner of their home not relevant if they separated before individual’s acquisition of another principal residence
Income Tax Act - Section 118.05 - Subsection 118.05(1) - Qualifying Home - Paragraph (a) allocation of credit between 2 qualifying spouses
Income Tax Act - Section 118.05 - Subsection 118.05(1) - Qualifying Home - Paragraph (a) - Subparagraph (a)(ii) ownership of secondary residence does not disqualify for HBTC
Income Tax Act - Section 118.05 - Subsection 118.05(1) - Qualifying Home - Paragraph (a) - Subparagraph (a)(i) given future intention test, there can be a gap between purchase and home becoming principal residence