We have translated 10 more CRA interpretations

We have published a further 10 translations of CRA interpretation released in February, 2008. We have also published a translation of a ruling released last week. Their descriptors and links appear below.

These are additions to our set of 1,557 full-text translations of French-language severed letters (mostly, Roundtable items and Technical Interpretations) of the Income Tax Rulings Directorate, which covers all of the last 13 1/3 years of releases of Interpretations by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for June.

Bundle Date Translated severed letter Summaries under Summary descriptor
2021-05-26 2021 Ruling 2020-0868661R3 F - Section 84.1 – Leveraged Buyout Income Tax Act - Section 84.1 - Subsection 84.1(1) s. 84.1 did not apply to a leveraged buyout financed by the target
Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) ruling that buyout was an arm’s length transaction
2008-02-29 18 February 2008 External T.I. 2006-0205321E5 F - BAA-corpropriété indivise, QFP-undivided interest Income Tax Act - Section 44 - Subsection 44(5) on partition and exchange of farms held by two brothers in equal co-ownership, the acquired 50% interests could qualify as replacement properties
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property a co-ownership interest in a farm can qualify as a qualified farm property
18 February 2008 External T.I. 2007-0228491E5 F - Heures travaillées hors décret de la CCQ Income Tax Act - Section 127 - Subsection 127(9) - Eligible Apprentice hours worked outside the scope of the CCQ (Commission de la construction du Québec) decree are ineligible
20 February 2008 External T.I. 2007-0232621E5 F - Pourboires versés électroniquement Income Tax Regulations - Regulation 100 - Subsection 100(1) - Employer “employer” can include agent that handles the payment of tips
25 February 2008 Internal T.I. 2007-0243871I7 F - Avantages imposables Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) unpaid director was a deemed employee, so that payment of his personal expenses was a s. 6(1)(a) benefit
Income Tax Act - Section 246 - Subsection 246(1) s. 246(1) only used as a fallback provision
2008-02-22 12 February 2008 External T.I. 2006-0217301E5 F - Actions admissibles de petite entreprise Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (c) - Subparagraph (c)(i) assets held through a trust do not qualify
15 February 2008 External T.I. 2007-0232041E5 F - Crédit pour la condition physique des enfants Income Tax Act - Section 118.03 - Subsection 118.03(2) eligible expenses could include mandatory affiliation fees
12 February 2008 Internal T.I. 2007-0240721I7 F - Crédit d'impôt pour frais médicaux Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(e) a riding school is not an “other place”
14 February 2008 Internal T.I. 2007-0256401I7 F - Vente d'un surplus actuariel Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) amount of asset sale price allocated to actuarial surplus was includible under s. 56(1)(a)(i) as being in lieu of refund of such surplus
2008-02-15 6 February 2008 External T.I. 2007-0239951E5 F - Restrictions à la déduction pour amortissement Income Tax Regulations - Regulation 1100 - Subsection 1100(11) rental property restriction rules are applied separately to directly held rental properties and those attributed to that taxpayer under s. 75(2)
6 February 2008 External T.I. 2007-0248161E5 F - Retenues à la source / Congédiement Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance retiring allowances include damages for anguish from wrongful dismissal/no CPP/EI withholding