We have translated 10 more CRA Interpretations

We have published a translation of a CRA interpretation released last week, and a further 9 translations of CRA interpretation released in January 2009, and in October and September, 2008. Their descriptors and links appear below.

These are additions to our set of 1,440 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 12 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
2021-03-17 23 June 2020 External T.I. 2020-0849761E5 F - SSUC - Entité déterminée et institution publique substantially the same as 2020-0848721E5 F
2009-01-16 6 January 2009 Internal T.I. 2008-0301721I7 F - Frais judiciaires et droit de propriété Income Tax Act - Section 54 - Adjusted Cost Base survey costs to remedy problems on previous land acquisition were addition to land ACB
2009-01-09 5 January 2009 External T.I. 2008-0294011E5 F - Choix d'exclure les travaux en cours Income Tax Act - Section 34 election can create a loss
Income Tax Act - Section 10 - Subsection 10(4) - Paragraph 10(4)(a) a services business generally values its WIP based on its hourly rates
2008-10-24 6 October 2008 External T.I. 2008-0271421E5 F - Terres à bois-plan d'aménagement forestier Québec Income Tax Act - Section 73 - Subsection 73(3) - Paragraph 73(3)(c) Quebec regional agencies’ plans for forest management plans would generally satisfy s. 73(3)(c), whose “engaged” requirement would be met if such plans did not require work
Income Tax Act - Section 70 - Subsection 70(9) - Paragraph 70(9)(a) “engaged” requirement in s. 70(9)(a) is satisfied to extent the forest management plan requires no action
Income Tax Act - Section 248 - Subsection 248(1) - Farming woodlot, to be a farm, must focus on the fostering of the stand
2008-09-19 16 September 2008 External T.I. 2008-0268021E5 F - Catégorie 43 - poinçon hydraulique Income Tax Regulations - Schedules - Schedule II - Class 43 hydraulic punch used in manufacturing processes of 3rd parties qualified
28 August 2008 External T.I. 2008-0287611E5 F - Surplus Stripping Income Tax Act - Section 84.1 - Subsection 84.1(1) s. 84.1 or GAAR would apply to series of transactions to convert a taxable dividend into proceeds of freeze shares
2008-09-05 19 August 2008 Internal T.I. 2008-0280681I7 F - Création d'emplois d'apprentis Income Tax Act - Section 127 - Subsection 127(9) - Apprenticeship Expenditure no pro-ration for short taxation years
27 August 2008 External T.I. 2008-0287951E5 F - Entreprises distinctes Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) a chain of retail stores operating under the same rules and procedures likely would be a single business
20 August 2008 External T.I. 2008-0288561E5 F - Convention de partage d'une société de personnes Income Tax Act - Section 96 - Subsection 96(1.1) no income could be allocated under s. 96(1.1) where aggregate income was nil
Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(c) - Subparagraph 53(2)(c)(v) payment to a retired partner in excess of partnership income is treated as a constructive withdrawal of capital by the other partners, reducing their ACB
Income Tax Act - 101-110 - Section 103 - Subsection 103(1) CRA generally does not challenge sharing agreements based on each partner’s contribution
29 August 2008 External T.I. 2008-0289971E5 F - Disposition d'un immeuble Income Tax Act - Section 54 - Principal Residence - Paragraph (a) residence did not qualify if sold before inhabited