We have translated 4 more CRA Interpretations

We 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