We have translated 10 more CRA interpretations

14 June 2021 - 11:51pm
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We have published a further 10 translations of CRA interpretation released in February and January, 2008, and December 2007. Their descriptors and links appear below.

These are additions to our set of 1,578 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 ½ 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
2008-02-01 22 January 2008 External T.I. 2006-0165521E5 F - Prime versé à l'emprunteur Income Tax Act - Section 13 - Subsection 13(7.1) no opinion expressed on whether a bonus received under the Quebec Immigrant Investor Program reduced the cost of the eligible capital property acquired
23 January 2008 External T.I. 2007-0236051E5 F - Frais de relocalisation Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) IT-178R3, IT-470R and T4130 should be referenced for question on employee relocation reimbursement and allowance
2008-01-18 8 January 2008 Internal T.I. 2007-0254881I7 F - Amortissement d'une aire de camping Income Tax Regulations - Schedules - Schedule II - Class 17 costs of developing a campground would generally be added to Class 17(c)
Income Tax Regulations - Regulation 1100 - Subsection 1100(17) campground, if a business, not subject to leasing property restriction rule
Income Tax Regulations - Schedules - Schedule II - Class 1 septic tanks are structures
Income Tax Regulations - Schedules - Schedule II - Class 6 swimming pool is a water storage tank
2008-01-11 5 December 2007 Internal T.I. 2007-0221211I7 F - Capital Dividends Income Tax Act - Section 184 - Subsection 184(3) Reversed by 2011-0412071C6 F and 2017-0709031C6 F
Income Tax Act - Section 165 - Subsection 165(3) suggesting awaiting by CRA of a court resolution of a related dispute would be contrary to its duty to act with all due dispatchReversed by 2011-0412071C6 F and 2017-0709031C6 F
Income Tax Act - Section 184 - Subsection 184(3) CRA will not accommodate appeal of underlying Pt. I and III assessments by agreeing to act on a waiver if appeal successful or by deferred processing of a s. 184(3) electionReversed by 2011-0412071C6 F and 2017-0709031C6 F
2 January 2008 External T.I. 2007-0228241E5 F - Programme canadien d'options familles agricoles Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(r) - Subparagraph 56(1)(r)(iv) payments under the Canadian Farm Families Options Program to those without a farming source of income would be included under s. 56(1)(r)(iv)
Income Tax Act - Section 9 - Computation of Profit payments under the Canadian Farm Families Options Program were business income to those with a farming source of income
Income Tax Act - Section 146 - Subsection 146(1) - Earned Income payments under the Canadian Farm Families Options Program to those without a farming source of income would be excluded from earned income
2007-12-28 18 December 2007 External T.I. 2007-0224761E5 F - Changement d'usage partiel et choix 45(3) Income Tax Act - Section 45 - Subsection 45(3) election not available where change from 20% to 100% personal use
2007-12-14 4 December 2007 Internal T.I. 2007-0237461I7 F - Définition d'activité de construction Income Tax Regulations - Regulation 238 - Subsection 238(2) construction activities included cable installation, maintenance and upgrading/primarily means over 50%
4 December 2007 Internal T.I. 2007-0255041I7 F - Employé de l'OTAN Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(a) Canadian-resident NATO employee’s income not exempted if the employee was seconded by Canada to NATO, or a Canadian military member
Income Tax Act - Section 146 - Subsection 146(1) - Earned Income income exempted under s. 81(1)(a) is not added to earned income
4 December 2007 Internal T.I. 2007-0255381I7 F - Dommages reçus suite à la perte d'un emploi Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance two judicial tests for what is a retiring allowance
2007-12-07 7 November 2007 Internal T.I. 2007-0253861I7 F - Partie non-imposable du gain en capital Income Tax Act - Section 132.1 - Subsection 132.1(2) no ACB increase under s. 132.1(2) if no previous reduction under s. 53(2)(h)(i.1)
Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(h) - Subparagraph 53(2)(h)(i.1) - Clause 53(2)(h)(i.1)(B) - Subclause 53(2)(h)(i.1)(B)(I) s. 53(2)(h)(i.1)(B)(I) designation does not increase unit ACB