We have translated 5 more CRA Interpretations
7 December 2020 - 10:40pm
Email this ContentWe have published 5 further translations of CRA interpretation released in September and August , 2009. Their descriptors and links appear below.
These are additions to our set of 1,336 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 11 1/3 years of releases of Interpretations by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. You are currently in the “open” week for December.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2009-09-25 | 28 August 2009 External T.I. 2009-0325881E5 F - Application of Subsection 89(8) | Income Tax Act - Section 89 - Subsection 89(8) | no deduction under element C for loss of target incurred in the year after the change of control |
| 2009-09-04 | 20 August 2009 Internal T.I. 2009-0326941I7 F - Intérêts, Taxe sur le capital, déductibilité | Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | provincial capital tax and interest thereon generally is deductible/income taxes are not |
| 2009-08-28 | 20 August 2009 External T.I. 2008-0294531E5 F - Placement admissible REÉR - Parts privilégiées RIC | Income Tax Act - Section 146 - Subsection 146(5) | premium can be paid in kind with contribution of shares, if validly issued |
| 2009-08-14 | 21 July 2009 Internal T.I. 2009-0322591I7 F - Déduction des intérêts | Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(b) | issuance of replacement promissory note for amount of previous principal plus capitalized interest was not a crediting of such interest |
| Income Tax Act - Section 248 - Subsection 248(1) - Disposition | replacement of note and capitalized interest by new note with increased amount did not constitute payment by novation of the old debt | ||
| General Concepts - Payment & Receipt | replacement of note with capitalized note with note for full amount did not constitute payment by novation | ||
| 2009-08-07 | 29 July 2009 External T.I. 2008-0297011E5 F - Conversion de participations dans une SNC | Income Tax Act - Section 248 - Subsection 248(1) - Disposition | no disposition if new partnerships interests exchanged for old interests that in totality are not substantially distinguishable |
| Income Tax Act - Section 97 - Subsection 97(2) | s. 97(2) rollover not available if new partnerships interests exchanged for old interests are not in totality substantially distinguishable | ||
| Income Tax Act - Section 96 - Subsection 96(1.01) | s. 96(1.01) inapplicable where only income interest and not capital interest disposed of | ||
| Income Tax Act - Section 43 - Subsection 43(1) | where only income interest and not capital interest in a partnership disposed of, there is part disposition of partnership interest with resulting reduced ACB for remainder interest |