We have translated 10 more CRA interpretations

5 July 2021 - 11:25pm
Email this ContentEmail this Content

We have published a further 10 translations of CRA interpretation released in October and September, 2007. Their descriptors and links appear below.

These are additions to our set of 1,612 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 ¾ 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 July.

Bundle Date Translated severed letter Summaries under Summary descriptor
2007-10-26 15 October 2007 External T.I. 2007-0239491E5 F - Prepayment of Reassessments Income Tax Act - Section 161 - Subsection 161(1) payments made in advance of a reassessment reduce arrears interest under s. 161(1)
10 October 2007 External T.I. 2007-0243601E5 F - Proposal - Taxation year end Income Tax Act - Section 128 - Subsection 128(1) person who made a successful proposal was not a bankrupt
12 October 2007 External T.I. 2007-0252941E5 F - OSBL et organisation agricole Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(e) "agricultural organization" has its ordinary meaning/ss. 149(1)(e) and (l) can overlap
2007-10-19 3 October 2007 External T.I. 2007-0230671E5 F - Paragraphe 12 du IT-338R2 Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) there is a s. 53(1)(e)(iv) basis bump for underlying debt under s. 98(5) wind-up
28 September 2007 External T.I. 2007-0241341E5 F - Crédit pour la condition physique des enfants Income Tax Act - Section 118.03 - Subsection 118.03(1) - Eligible Fitness Expense summer or sports camp is ineligible if not for a period of at least five consecutive calendar days
2007-10-05 25 September 2007 Internal T.I. 2007-0226751I7 F - Gain en capital versus revenu d'entreprise Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(b) property regular refurbished for leasing then resale at a gain was inventory
Income Tax Act - Section 9 - Capital Gain vs. Profit - Machinery and Equipment the regular refurbishing, rental then sale at a gain of machines gave rise to business profits
21 September 2007 External T.I. 2007-0229191E5 F - Agent de voyages & impôt de la partie I.3 Income Tax Act - Section 181 - Subsection 181(3) - Paragraph 181(3)(b) - Subparagraph 181(3)(b)(i) customer advances received by travel agents and reported as deferred revenue in their balance sheets were required to be included in taxable capital even though amounts held in trust
Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(c) customer advances received by travel agents and reported as deferred revenue in their balance sheets were “advances”
20 September 2007 External T.I. 2007-0248451E5 F - Donation lors d'un encan Income Tax Act - Section 248 - Subsection 248(30) s. 248(30) has no impact in Quebec
26 September 2007 External T.I. 2007-0252621E5 F - Crédit pour la création d'emplois pour apprentis Income Tax Act - Section 127 - Subsection 127(9) - Investment Tax Credit - Paragraph (m) 12 month extension also applies to AJCTC
2007-09-28 13 September 2007 External T.I. 2006-0214631E5 F - Déboursé pour usufruit ou droit d'usage Income Tax Act - Section 248 - Subsection 248(3) instalments of purchase price for usufruct were cost of capital interest in a trust