We have translated 10 more CRA interpretations
30 August 2021 - 11:03pm
Email this ContentWe have published a further 10 translations of CRA interpretation released in February, 2007. Their descriptors and links appear below.
These are additions to our set of 1,692 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 14 ½ years of releases of such items by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for September.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2007-02-23 | 12 February 2007 External T.I. 2006-0214141E5 F - Régime d'assurance salaire | Income Tax Act - Section 15 - Subsection 15(1) | benefit from corporate employer’s payment of premiums under disability plan restricted to the two shareholder-managers was received qua shareholder rather than employee |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | a qualifying group disability plan could utilize individual policies, but s. 6(1)(a)(i) exclusion not available where plan restricted to the two shareholder-managers | ||
| 15 February 2007 External T.I. 2006-0216851E5 F - REÉÉ - Définition de fiducie | Income Tax Act - Section 146.1 - Subsection 146.1(1) - Trust - Paragraph (d) | quaere whether payer can have control rights over the use of the RESP proceeds by university | |
| 16 February 2007 External T.I. 2006-0200541E5 F - Prestation universelle pour la garde d'enfants | Income Tax Act - Section 74.1 - Subsection 74.1(2) | UCCB benefit put into separate bank account for child subject to attribution | |
| 2007-02-16 | 12 February 2007 External T.I. 2006-0205981E5 F - DAS programme de soutien financier pour handicapés | Income Tax Regulations - Regulation 100 - Subsection 100(1) - Remuneration - Paragraph (h) | assistance paid to those with disabilities to assisting taking up employment was “remuneration” subject to source deductions |
| Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(r) | assistance paid to those with disabilities to assisting taking up employment came within s. 56(1)(r) | ||
| 18 December 2006 Internal T.I. 2006-0208611I7 F - Indemnités pour lésions professionnelles | Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(v) | application of ss. 56(1)(v) and 110(1)(f)(ii) to non-contractual amounts paid by bank pursuant to Canada Labour Code to Ontario employees, not in excess of the WSIB scales | |
| Income Tax Regulations - Regulation 232 - Subsection 232(4) | Reg. 232(4) exclusions are broader than those listed | ||
| 22 January 2007 External T.I. 2006-0212641E5 F - Crédit de taxe sur le capital du Québec | Income Tax Act - Section 13 - Subsection 13(7.1) | Quebec tax credit for qualified investments is government assistance recognized under s. 13(7.1) rather than s. 12(1)(x) | |
| Income Tax Act - Section 127 - Subsection 127(11.1) - Paragraph 127(11.1)(b) | Quebec tax credit for qualified investments is deducted under s. 127(11.1)(b) in accordance with the ITTN No. 29 timing | ||
| 25 January 2007 External T.I. 2006-0213961E5 F - Rémunération, assurance salaire, indemnité CSST | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) - Subparagraph 6(1)(f)(iii) | wage maintenance amount paid in advance of workers’ compensation was reportable as s. 6(1)(f)(iii) income, with s. 8(1)(n) deduction when repaid after receipt under s. 56(1)(v) | |
| Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(v) | amount paid by employer in advance of workers’ compensation was reportable as s. 6(1)(f)(iii) income, with the employee later taking a s. 8(1)(n) deduction and a s. 56(1)(v) inclusion | ||
| 6 February 2007 External T.I. 2006-0170921E5 F - Capital Gain Strip | Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(ii) | s. 55(3)(a)(ii) exclusion applies when Opco, in which two unrelated individuals having special voting shares, spins off real estate to Opco’s Holdco | |
| 16 November 2006 External T.I. 2006-0203131E5 F - Régime à traitement différé | Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(1)(a)(v) | failure for leave to be taken at the end of the deferral period | |
| Income Tax Act - Section 5 - Subsection 5(1) | advances received were salary rather than loans and, when repaid, reduced employment income | ||
| 2007-02-09 | 26 January 2007 External T.I. 2005-0157751E5 F - Don d'un duplex et changement d'usage | Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | generally appropriate to allocate the deemed proceeds between residence and rental portion on building square footage basis, with land to follow suit |
| Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(b) | 1/2 step-up limitation where change of use |