Our translations of CRA Interpretations go back over 13 years

4 May 2021 - 10:00am
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We have published a further 10 translations of CRA interpretation released in May and April, 2008. Their descriptors and links appear below.

These are additions to our set of 1,516 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 13 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 May.

Bundle Date Translated severed letter Summaries under Summary descriptor
2008-05-09 1 May 2008 External T.I. 2007-0250141E5 F - Crédit pour la création d'emplois d'apprentis Income Tax Act - Section 127 - Subsection 127(9) - Eligible Apprentice issuance of 1st apprenticeship competency certificate is an indicator of the beginning of an apprenticeship
30 April 2008 External T.I. 2007-0252051E5 F - Commercial Woodlot - Timber Limit Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(e) standing timber on purchased land is a timber limit
30 April 2008 External T.I. 2007-0254311E5 F - Estate Freeze - Attribution Rules Income Tax Act - Section 74.4 - Subsection 74.4(4) condition can be satisfied where the minor child’s beneficial interest is held through two personal trusts
30 April 2008 External T.I. 2007-0257041E5 F - Crédit pour la création d'emplois d'apprentis Income Tax Act - Section 127 - Subsection 127(9) - Eligible Apprentice industry concept of 2000 hours per apprenticeship “year” was inapplicable
Statutory Interpretation - Interpretation Act - Section 37 - Subsection 37(1) “year” refers to any 12-month period
2008-05-02 21 April 2008 External T.I. 2007-0220471E5 F - Excessive Capital Dividend and 220(3.2) Income Tax Act - Section 184 - Subsection 184(4) no s. 184(4) election available where one of the shareholders was dissolved
Income Tax Act - Section 220 - Subsection 220(3.2) s. 220(3.2) revocation is an alternative if a s. 184(4) election cannot be made
21 April 2008 Internal T.I. 2007-0251761I7 F - Billet à payer Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(d) addition of unpaid interest to principal did not establish a loan of that interest or a novation of the debt – so that interest on such capitalized interest non-deductible until paid
Income Tax Act - Section 212 - Subsection 212(1) addition of unpaid interest to principal was not a payment or crediting of the interest so as to engage Pt. XIII tax
General Concepts - Payment & Receipt addition of unpaid interest to principal was not a loan of money, nor a payment or crediting of interest
22 April 2008 External T.I. 2005-0152261E5 F - Interaction 24(2) et 14(3) Income Tax Act - Section 24 - Subsection 24(2) s. 14(3) takes precedence over s. 24(2)
2008-04-25 15 April 2008 External T.I. 2006-0216791E5 F - Frais de déplacement-Personnel VS Aff. Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) travel of school trustee between home and administrative office where meetings were held was a personal expense, whose reimbursement was taxable
11 April 2008 Internal T.I. 2007-0239621I7 F - Crédit d'impôt pour pers. entièrement à charge Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) taxpayer to whom a youth centre had placed a child and was no longer receiving compensation could potentially claim the credit
10 April 2008 External T.I. 2008-0265761E5 F - Avantage imposable - Programme écoAuto Income Tax Act - Section 6 - Subsection 6(2) ecoAUTO program reduced the cost for standby benefit computation purposes