We have translated 5 more CRA Interpretations
28 September 2020 - 11:11pm
Email this ContentWe have published a further 5 translations of CRA interpretations released in February and January, 2010. Their descriptors and links appear below.
These are additions to our set of 1,278 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 2/3 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 October.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2010-02-05 | 15 January 2010 External T.I. 2009-0343841E5 F - Application du paragraphe 127(10.22) | Income Tax Act - Section 127 - Subsection 127(10.22) | interposition of Holdco broke a condition for application of s. 127(10.22) |
| 1 February 2010 Internal T.I. 2010-0354671I7 F - Frais de gestion à une fiducie | Income Tax Act - Section 67 | CRA policy of not challenging reasonableness of bonuses paid by CCPC to an individual holding through Holdco does not apply where individual holds through trusts | |
| 21 December 2009 Internal T.I. 2008-0296131I7 F - Fraction à risque | Income Tax Act - Section 96 - Subsection 96(2.2) - Paragraph 96(2.2)(c) | exception from s. 96(2.2)(c) for legitimate business loans from related parties | |
| 14 January 2010 Internal T.I. 2009-0323991I7 F - Débenture échangeable et opération à terme | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) | only ½ deduction under s. 20(1)(f)(ii) for premium paid on cash-settling an exchangeable debenture under pre-2010 policy, and no s. 20(1)(f) deduction for cash settlement of forward | |
| Income Tax Act - Section 9 - Capital Gain vs. Profit - Futures/Forwards/Hedges | premium was paid on capital account in closing out a cash-settled forward entered into in order to monetize a shareholding | ||
| Income Tax Act - Section 152 - Subsection 152(1) | CRA position of applying changes in published policy prospectively | ||
| Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | full deduction of amounts only partly, or not, deductible under s. 20(1)(f) would have caught the eye of a wise and prudent person reviewing the return | ||
| 2010-01-29 | 26 January 2010 External T.I. 2009-0344121E5 F - REER, déduction pour cotisations excédentaires | Income Tax Act - Section 146 - Subsection 146(8.2) - Paragraph 146(8.2)(c) | a reference in Part I to a notice of assessment refers to a Part I notice of assessment |