We have translated 5 more CRA Interpretations

17 August 2020 - 11:32pm
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We have published a further 5 translations of CRA interpretations released in April and March, 2010. Their descriptors and links appear below.

These are additions to our set of 1,246 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 1/3 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
2010-04-09 5 March 2010 Internal T.I. 2009-0346261I7 F - Minimisation des pertes Income Tax Act - Section 112 - Subsection 112(3.2) - Paragraph 112(3.2)(b) a testamentary trust can qualify as an estate beneficiary for s. 112(3.2)(b) purposes
Income Tax Act - Section 112 - Subsection 112(3.2) - Paragraph 112(3.2)(a) respective purviews of ss. 112(3.2)(a)(ii)(A), (B) or (C)
Income Tax Act - 101-110 - Section 104 - Subsection 104(2) the trust and trustees both considered to be an individual respecting the corpus and thus to own it
15 March 2010 Internal T.I. 2009-0323081I7 F - Frais pour droit d'usage Income Tax Act - Section 6 - Subsection 6(2) - Element B travel in employer’s car from employer to home the night before is personal use, and the drive to the customer and from there to employer is not personal
26 March 2010 External T.I. 2009-0350821E5 F - Montant assurable et ouvrant droit à pension Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(c) value of housing is business income rather than being deductible under s. 8(1)(c) if pastor receives contributions from congregation as business income
2010-04-02 25 March 2010 External T.I. 2009-0308851E5 F - Transactions de valeurs mobilières Income Tax Act - Section 9 - Capital Gain vs. Profit - Shares weighing of factors in IT-479R, para. 11 re the presence of a trading business
2010-03-26 25 February 2010 External T.I. 2009-0352231E5 F - OBNL, profits, perte de statut, gain en capital Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) holding of surplus funds permissible only for funding a specific project
Income Tax Act - Section 84 - Subsection 84(2) s. 84(2) inapplicable to winding-up of non-share corp