We have translated 5 more CRA Interpretations

1 September 2020 - 12:06am
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We have published a further 5 translations of CRA interpretations released in March, 2010. Their descriptors and links appear below.

These are additions to our set of 1,256 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. Next week is the open week for September.

Bundle Date Translated severed letter Summaries under Summary descriptor
2010-03-12 22 December 2009 Internal T.I. 2009-0343331I7 F - Determination of CCPC Status Income Tax Act - Section 256 - Subsection 256(5.1) de facto control given control of financing and significant influence on decisions
Income Tax Act - Section 220 - Subsection 220(2.2) s. 220(2.2) precluded accepting a late amendment
Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation shareholder agreement affecting how the majority of directors exercised their rights was not a USA
17 February 2010 Internal T.I. 2009-0348461I7 F - Transfert d'une PCMC à une société mère Income Tax Regulations - Schedules - Schedule II - Class 10 - Paragraph 10(x) full cost of CFVPs acquired by parent from production sub (which claimed the credits) added to Class 10(x)
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Current expense vs. capital acquisition fully claimed films productions acquired from production sub on capital account
4 March 2010 Internal T.I. 2009-0337381I7 F - Sens du mot divertissement Income Tax Act - Section 67.1 - Subsection 67.1(1) s. 67.1 limitation does not apply to gifts of equipment used to entertain the recipient
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) gifts of entertainment equipment by taxpayer to an employee of a customer responsible for purchases are includible in that individual’s income
2010-03-05 19 January 2010 External T.I. 2009-0344681E5 F - Récompenses visées par règlement Income Tax Regulations - Regulation 7700 literary prizes were sufficiently recognized by the general public to be prescribed
23 February 2010 Internal T.I. 2010-0356121I7 F - Avantage imposable - appareils auditifs Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) hearing aid reimbursement was taxable given that employee owned the devices and primarily benefited