We have translated 5 more CRA Interpretations

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

These are additions to our set of 1,230 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 ¼ 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 August.

Bundle Date Translated severed letter Summaries under Summary descriptor
2010-05-07 28 April 2010 External T.I. 2009-0347581E5 F - Frais de formation Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Know-How and Training distinction between training and convention expenses/luncheon seminar fees on case law generally are professional deductions
Income Tax Act - Section 20 - Subsection 20(10) convention expenses providing an enduring benefit may be deducted within the s. 20(10) limitations
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose expense incurred in course of operating real property need not have a direct effect on profit
21 April 2010 External T.I. 2009-0341711E5 F - Déduction pour gains en capital Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(d) beneficiary of trust partner can access deduction
2010-04-30 20 April 2010 External T.I. 2010-0355071E5 F - Ligne directrice 4 Other Legislation/Constitution - Federal - Indian Act - Section 87 Indian organization did not qualify under Guideline 4 where 20% of clientele lived off reserve
Income Tax Act - Section 2 - Subsection 2(1) central management and control of Indian organization is at the main office if control is legitimately exercised at meetings conducted there
16 April 2010 Internal T.I. 2010-0362601I7 F - Établissement stable-Province Income Tax Regulations - Regulation 400 - Subsection 400(2) - Paragraph 400(2)(e) CRA will accept shorter presence of substantial equipment at concerts than 30 days as representing PEs of the non-resident performance corporation
28 April 2010 External T.I. 2010-0362101E5 F - Déductibilité des intérêts Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) under current use test, deductible interest increased to 100% when unit in triplex converted to rental use