We have translated 6 more CRA Interpretations

We have published a further 6 translations of CRA interpretations released in April, 2010. Their descriptors and links appear below.

These are additions to our set of 1,236 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. You are currently in the “open” week for August.

Bundle Date Translated severed letter Summaries under Summary descriptor
2010-04-30 14 April 2010 Internal T.I. 2009-0347511I7 F - Partie I.3 - Société de personnes Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(g) s. 181.2(3)(g) was to be applied on basis that partnership interest and debt held by a Crown agent was held by the Quebec government, being a corporation
Income Tax Act - Section 248 - Subsection 248(1) - Corporation Quebec government is a corporation
2010-04-23 13 April 2010 External T.I. 2010-0358941E5 F - CIRD - franchise Income Tax Act - Section 118.04 - Subsection 118.04(1) - Qualifying Expenditure qualifying expenditure generally not reduced by insurance reimbursement
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense expense generally incurred by taxpayer even where reimbursed by insurance company
14 April 2010 External T.I. 2010-0356901E5 F - RAP- Rétroactivité Income Tax Act - Section 146.01 - Subsection 146.01(1) - Regular Eligible Amount - Paragraph (e) ownership of a home whose purchase was voided did not count
7 April 2010 External T.I. 2010-0355221E5 F - Paragraphes 145(5) et 122(2) Income Tax Act - Section 149 - Subsection 149(5) NPO settled before 1972 is not grandfathered
12 April 2010 Internal T.I. 2009-0342871I7 F - Subvention aux naissances multiples Income Tax Act - Section 3 Quebec multiple birth subsidy is not income
14 April 2010 External T.I. 2008-0293981E5 F - Loi de 2007 sur les impôts de l'Ontario Other Legislation/Constitution - Ontario - Taxation Act 2007 - Section 46 - Subsection 46(1) - Transition Time amalgamation in 2008 results in a transition time corresponding to the amalgamation time
Other Legislation/Constitution - Ontario - Taxation Act 2007 - Section 46 - Subsection 46(1) - Eligible pre-2009 Winding-up completion time does not occur until formal dissolution