We have published 10 more translations of CRA interpretations
25 October 2021 - 10:40pm
Email this ContentWe have published a further 10 translations of CRA interpretation released in September, August and July, 2006. Their descriptors and links appear below.
These are additions to our set of 1,776 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 15 ¼ 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 November.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2006-09-08 | 1 November 1994 Internal T.I. 94234170 F - CBR Assurance-vie | Income Tax Act - Section 148 - Subsection 148(9) - Disposition | amendment to policy to reduce premiums and insured amounts was not intended to create a new policy, and was not a disposition |
| Income Tax Act - Section 248 - Subsection 248(1) - Disposition | amending policy to reduce premiums and insured amount was not a disposition | ||
| 2006-08-18 | 20 June 2006 External T.I. 2005-0149651E5 F - CEE / FEC | Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | expenditures to ensure safety of exploration personnel generally qualify if not specifically excluded |
| 2006-08-11 | 18 July 2006 External T.I. 2005-0159781E5 F - Paragraph 55(3)(a) | Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(i) | ss. 55(3)(a)(i) to 55(3)(a)(v) not engaged where Holdco spins off Subco to Sisterco and then redeems the minority shareholding in Holdco of 3rd party |
| 18 July 2006 External T.I. 2005-0162181E5 F - Subsection 74.4(2) | Income Tax Act - Section 74.4 - Subsection 74.4(2) - Paragraph 74.4(4)(a) | a 9% spousal shareholder is a specified shareholder if she also controls a related corporation | |
| Income Tax Act - Section 248 - Subsection 248(1) - Specified Shareholder | 9% shareholder of corporation otherwise held by her spouse becomes a specified shareholder if she wholly-owns a second corporation | ||
| 29 June 2006 External T.I. 2006-0170641E5 F - Distribution of Corporate Property | Income Tax Act - Section 84 - Subsection 84(2) | 12 month maintenance of business of pipeline corporation contributes to favourable s. 84(2) ruling | |
| 18 July 2006 Internal T.I. 2006-0184431I7 F - Prêt d'un gouvernement | Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iii) | ultimate obligation to repay all the amount advanced rendered a loan an unconditional loan rather than a forgivable loan | |
| 1 June 1993 External T.I. 93061850 - Prestations d'assurance-salaire | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) | benefits under wage loss insurance plan were taxable to employees because they had not fully borne the premiums (but s. 6(1)(f)(v) deductions available) | |
| 2006-07-28 | 11 July 2006 External T.I. 2006-0182451E5 F - Indemnité versée par un syndicat | Income Tax Act - Section 8 - Subsection 8(5) | payments by union to members to attend union conventions on their days off reduce the union dues deduction |
| Income Tax Act - Section 3 - Paragraph 3(a) | payments by union to members to attend union conventions on their days off not taxable | ||
| 20 July 2006 External T.I. 2005-0124101E5 F - Avantages imposables à des employés | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | a working meal potentially could be excluded | |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(v) | exemption inapplicable where union employee negotiating contract is employed by different union | ||
| Income Tax Act - Section 248 - Subsection 248(1) - Office | temporary position of unionized employee with union is an "office" | ||
| 11 July 2006 External T.I. 2005-0152031E5 F - Actions admissibles de petite entreprise | Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation | building used 75% in the corporation’s active business operations and 25% for rental use would qualify | |
| Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(7) - Paragraph 110.6(7)(b) | transfer of property to corporation for a s. 85 agreed amount less than FMV of the property and the shares issued therefor does not engage s. 110.6(7)(b) |