Our translations of CRA Interpretations go back over 11 years

We have published 5 further translations of CRA interpretation released in November and October, 2009. Their descriptors and links appear below.

These are additions to our set of 1,326 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
2009-11-06 16 October 2009 Internal T.I. 2009-0337721I7 F - Perte lors de fusion étrangère Income Tax Act - Section 87 - Subsection 87(8) claiming of capital loss in promptly-filed amended return would be accepted as an election
Income Tax Act - Section 40 - Subsection 40(3.5) - Paragraph 40(3.5)(b) s. 40(3.4) not applicable to foreign triangular merger to which s. 87(8) was elected not to apply
2009-10-30 20 October 2009 External T.I. 2009-0328441E5 F - Fiducie testamentaire Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(a) unlikely to have been a distribution as a consequence of death where mooted testamentary trust formed by beneficiaries by their own agreement
Income Tax Act - Section 75 - Subsection 75(2) s. 75(2) would apply if heirs form a trust to provide for their sister out of the residue, with the remainder to them on her death
23 October 2009 External T.I. 2009-0309861E5 F - Tax-free Savings Accounts Income Tax Act - Section 143.2 - Subsection 143.2(2) - Paragraph 146.2(2)(c) contribution by spouse causes cessation as TFSA
Income Tax Act - Section 74.5 - Subsection 74.5(12) - Paragraph 74.5(12)(c) s. 74.5(12)(c) inapplicable to contribution of property to TFSA of contributor’s spouse followed by spouse’s withdrawal of property and investment of proceeds
20 October 2009 External T.I. 2009-0327911E5 F - Fiducie non-résidente Contribuant résidant Income Tax Act - Section 94 - Subsection 94(1) - Resident Contributor any period of residence in Canada even if prior to a period when the person was non-resident in Canada is included in computing the 60-month period
2009-10-23 13 October 2009 External T.I. 2009-0342091E5 F - Revenu d'emploi exonéré par Conv.- frais de garde Treaties - Income Tax Conventions - Article 19 employment income that was Treaty-exempt was to be reported (on a separate line), with the s. 110(1)(f)(i) deduction then claimed
Income Tax Act - Section 63 - Subsection 63(2) child care expenses could only be claimed by the spouse with the lower net income, notwithstanding that her income was Treaty-exempt