We have translated 7 more CRA Interpretations

We have published translations of the 2 CRA interpretations that were released last week, as well as of a further 5 CRA interpretation released in November, 2009. Their descriptors and links appear below.

These are additions to our set of 1,315 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 11 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
2020-11-04 13 August 2020 External T.I. 2019-0802891E5 F - Unclaimed RRSP Benefits Income Tax Act - Section 146 - Subsection 146(1) - Benefit - Paragraph (a) benefit includible in deceased annuitant’s return was not subject to (a) exclusion because it was not reported
Income Tax Act - Section 146 - Subsection 146(8) s. 146(8) benefit paid to the taxpayer’s administrator was not includible in her income until the year she was identified and received the amount
Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(c) tax imposed on RRSP under s. 146(4)(c) where RRSP issuer unaware of annuitant’s death
General Concepts - Payment & Receipt constructive receipt of amount deducted on account of fees that were the recipient’s obligation
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose fees incurred as a consequence of receiving unclaimed property (which was taxable under s. 146(8)) were non-deductible
Income Tax Act - Section 9 - Timing receipt of income by an administrator was not income of the beneficial owner until the year she was identified
22 June 2020 External T.I. 2017-0728051E5 F - Land inventory Income Tax Act - Section 70 - Subsection 70(5.2) “land” includes buildings and other improvements
2009-11-27 16 November 2009 External T.I. 2009-0313081E5 F - Classification d'un chemin de fer avant 1958 Income Tax Regulations - Schedules - Schedule II - Class 4 railway system acquired by common carrier before 1958 falls within Class 4
16 November 2009 Internal T.I. 2009-0342571I7 F - Catégorie 1, alinéa 1100(1)a.1) du Règlement Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(a.1) it is landlord, not the tenant, who claims the building CCA
2009-11-20 2 November 2009 External T.I. 2009-0308741E5 F - Fonds de formation Income Tax Act - Section 248 - Subsection 248(1) - Employee Benefit Plan - Paragraph (d) para. (d) exclusion did not apply where the training related to other work
5 November 2009 External T.I. 2009-0333031E5 F - Taxes foncières et scolaires Income Tax Act - Section 18 - Subsection 18(2) municipal taxes deductible against rental income but not gain from resale
9 November 2009 External T.I. 2009-0337281E5 F - Paris sportifs sur Internet Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit earning of $20,000 from sports betting indicated it was a business