We have published 10 more CRA translations

17 May 2021 - 10:42pm
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We have published a further 10 translations of CRA interpretation released in April and March, 2008. Their descriptors and links appear below.

These are additions to our set of 1,536 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.

Bundle Date Translated severed letter Summaries under Summary descriptor
2008-04-04 27 March 2008 External T.I. 2006-0200451E5 F - Syndicat de copropriétaires Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) distribution of land by Quebec condominium syndicate would cause it to lose its NPO status
Income Tax Act - Section 248 - Subsection 248(1) - Corporation condominium syndicate described in CCQ Art. 1039 is a corporation
Income Tax Act - Section 15 - Subsection 15(1) the co-owners of a Quebec syndicate were to be viewed as members of a corporation, so that s. 15(1) applied to a distribution to them
26 March 2008 External T.I. 2007-0224771E5 F - Sommes reçues en échange de références de clients Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit one-off referral fees to clients are likely non-taxable
Income Tax Regulations - Regulation 200 - Subsection 200(1) one-off referral fees to clients, if non-taxable, do not require T4As
26 March 2008 Internal T.I. 2007-0260291I7 F - Biens de pêche admissibles Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(2.2) deduction not available for pre-2006 fishing licence gain carried forward to 2006
2008-03-21 12 March 2008 External T.I. 2007-0222751E5 F - Crédit d'impôt création emploi apprenti Income Tax Regulations - Regulation 7310 construction trades that are not directly regulated by the Quebec government also generally qualify as Red Seal trades
13 March 2008 External T.I. 2008-0270151E5 F - Frais de location d'une automobile Income Tax Act - Section 6 - Subsection 6(2) - Element E lease costs include admin charges of the fleet management company
2008-03-14 5 March 2008 External T.I. 2007-0256291E5 F - Bénévoles Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) volunteers working regular hours for a charity were not taxable when charity’s automobile made available to them to commute to work or receive a small allowance or meal or car expenses
Income Tax Regulations - Regulation 200 - Subsection 200(1) requirement to report on T4A amounts paid to service provider greater than $500 inapplicable to charity volunteers who donate the amount back to the charity
5 March 2008 External T.I. 2007-0231831E5 F - Roulement de biens Income Tax Act - Section 44 - Subsection 44(1) - Paragraph 44(1)(a) court-directed sale of co-owned property as a substitute for partition is not a “taking” by either co-owner of the other’s property
Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (d) court-directed sale by partition court does not generate proceeds under para. (d)
6 March 2008 External T.I. 2007-0253561E5 F - Placement admissible REÉR Income Tax Act - Section 262 London AIM not a designated exchange
2008-03-07 27 February 2008 Internal T.I. 2008-0265901I7 F - Canadian-controlled private corporation Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation - Paragraph (b) terms of USA are ignored in applying the “purely arithmetic” test in para. (b)
3 March 2008 External T.I. 2007-0226201E5 F - RS&DE - Formulaires et renseignements prescrits Income Tax Act - Section 37 - Subsection 37(11) failure of sub to file T661 performed on its behalf by parent would not preclude a s. 9 deduction by it or a claim of its parent for deductions or ITCs