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