We have translated 6 more CRA Interpretations

We have published a translation of an interpretation released last week by CRA and a further 5 translations of CRA interpretations released in May, 2010. Their descriptors and links appear below.

These are additions to our set of 1,225 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
2020-07-15 12 June 2020 External T.I. 2018-0788161E5 F - Adjusted stub period accrual amount Income Tax Act - Section 34.2 - Subsection 34.2(1) - Adjusted Stub Period Accrual Income - Paragraph (a) - Element B ASPA not reduced by s. 111(1)(e) losses
2010-05-14 5 May 2010 External T.I. 2010-0359791E5 F - Significant increase - redemption of shares Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(ii) s. 55(3)(a)(ii) or (v) likely applicable where related shareholder’s prefs are partially redeemed - even if matching partial redemption of arm’s length pref shareholder 1 hr later
Income Tax Act - Section 86 - Subsection 86(1) s. 86 reorg where exchange of common for prefs followed by subscription for (old) commons
3 May 2010 Internal T.I. 2010-0359631I7 F - Dépenses liées à une résidence non habitée Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(h) ACB addition for property taxes inapplicable where a building on the property
Income Tax Act - Section 54 - Adjusted Cost Base property taxes not added to ACB of inherited property before its sale
4 May 2010 External T.I. 2009-0329391E5 F - Provision pour retour de marchandises Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) no reserve where book publisher’s customers could return unsold books, cf. where a "true" clause for the return of unsold goods
Income Tax Act - Section 9 - Timing no profit required to be recognized on delivery of goods where a "true" return of unsold goods clause
2010-05-07 3 May 2010 External T.I. 2010-0358881E5 F - CIRD - construction d'un logement Income Tax Act - Section 118.04 - Subsection 118.04(1) - Eligible Dwelling - Paragraph (a) qualifying expenditure for property acquired before completion of home’s construction but applied to renovation work after individual moved in
General Concepts - Ownership individual is considered to be owner of home that is being constructed as soon as it is habitable
3 May 2010 External T.I. 2010-0358471E5 F - Capital dividend account - beneficiary of a trust Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (g) capital dividend distributed by trust in its year and designated under s. 104(20) is added to corporate beneficiary’s CDA only at end of trust’s taxation year