We have translated 4 more CRA Interpretations
4 January 2021 - 10:45pm
Email this ContentWe have published a further 4 translations of CRA interpretation released in June 2009. Their descriptors and links appear below.
These are additions to our set of 1,358 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. You are currently in the “open” week for January.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2009-06-26 | 27 May 2009 External T.I. 2008-0296731E5 F - Rachat d'actions: 20(1)c) | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | corporation must allocate contributed capital of redeemed shares proportionately to borrowed money and redemption notes, but can disproportionately allocate its accumulated profits |
| 12 June 2009 External T.I. 2009-0316511E5 F - Charges sociales et autres retenues France | Treaties - Income Tax Conventions - Article 18 | list of pension plans recognized for French tax purposes re Art. XXIX(5) of French Treaty | |
| Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | social security contributions do not qualify as income taxes – but French "contribution sociale généralisée" and "contribution pour le remboursement de la dette sociale" so qualify | ||
| 2009-06-19 | 10 June 2009 External T.I. 2008-0300041E5 F - Paiements ou remboursement de frais de formation | Income Tax Act - Section 5 - Subsection 5(1) | bonus taxable even where employee requests that it be spent on skills training |
| 10 June 2009 External T.I. 2009-0308031E5 F - Admissibilité partagée de la PFCE | Income Tax Act - Section 122.6 - Eligible Individual - Paragraph (f) | factors in Reg. 6302 applied to determine which parent has primary care responsibility – if indeterminate, CRA applies its shared eligibility policy |