We have translated 5 more CRA Interpretations
We have published a further 5 translations of CRA interpretation released in June 2009. Their descriptors and links appear below.
These are additions to our set of 1,363 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.
|Bundle Date||Translated severed letter||Summaries under||Summary descriptor|
|2009-06-19||12 June 2009 Internal T.I. 2009-0324511I7 F - Déductibilité des primes payées||Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit||substantial commissions generated to broker on policies where he paid the premiums were taxable given their substantial amount|
|Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h)||premiums paid by broker on policies on which the insureds were family members were non-deductible notwithstanding that the related commissions earned by him were taxable|
|4 May 2009 External T.I. 2008-0299841E5 F - Garantie pour l'impôt de départ||Income Tax Act - Section 220 - Subsection 220(4.5)||posting of security for departure tax can generate refund of instalments paid in excess of regular tax|
|Income Tax Act - Section 164 - Subsection 164(7)||refund of instalments paid in excess of Part I tax for year ignoring s. 128.1(4) departure tax permitted where s. 220(4.5) security posted for such departure tax|
|8 June 2009 External T.I. 2009-0314301E5 F - Société d'État provinciale, production T2||Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(a)||provincial Crown corporations not required to file T2 returns and forms|
|2009-06-12||27 May 2009 External T.I. 2008-0303971E5 F - Transfer of a life insurance policy||Income Tax Act - Section 148 - Subsection 148(7)||gain under s. 148(7) on drop down of policy (with CSV exceeding its ACB) by individual to his corp.|
|3 June 2009 External T.I. 2009-0310231E5 F - Exonération des gains en capital||Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(d)||24-month test in para. (b) of QSBCS definition met where during part of 24-month period, mooted QSBCS were held through a general partnership|