We have translated 4 more CRA Interpretations
We have published a translation of a CRA interpretation released last week and a further 3 translations of CRA interpretation released in July and June, 2009. Their descriptors and links appear below.
These are additions to our set of 1,354 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 11 1/2 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 January.
|Bundle Date||Translated severed letter||Summaries under||Summary descriptor|
|2020-12-23||3 November 2020 External T.I. 2020-0848881E5 F - SSUC/CEWS - rémunération admissible||Income Tax Act - Section 125.7 - Subsection 125.7(1) - Eligible Remuneration - Paragraph (c)||eligible remuneration is not reduced where the eligible entity on-charges a portion of its employees' time to an affiliate|
|2009-07-03||25 June 2009 Internal T.I. 2009-0328171I7 F - Pénalité pour omission - 163(1)||Income Tax Act - Section 163 - Subsection 163(1)||s. 163(1) cannot apply where the previous year’s failure was in claiming bogus expenses rather than failing to report revenues|
|2009-06-26||11 May 2009 External T.I. 2008-0276761E5 F - Class 43.1 and 43.2||Income Tax Regulations - Schedules - Schedule II - Class 43.1||wood waste fuelled heat production system and ground source heat pump likely could qualify|
|Income Tax Regulations - Regulation 1104 - Subsection 1104(13) - Eligible Waste Fuel||wood pellets are wood waste|
|12 June 2009 Internal T.I. 2008-0294921I7 F - Montant reçu à l'égard d'un surplus actuariel||Income Tax Act - Section 9 - Nature of Income||lump sum paid to asset vendor for actuarial surplus in transferred pension plan was s. 9 income under Ikea expense-adjustment principle|
|Income Tax Act - Section 248 - Subsection 248(1) - Superannuation or Pension Benefit||transfer of a pension plan assets and liabilities to the asset purchaser with regulatory approval entailed a plan “modification” rendering actuarial surplus compensation taxable|