We have published 10 more translations of CRA interpretations

8 November 2021 - 10:41pm
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We have published 8 translations of CRA interpretation released between May 2011 and November 2006, which we translated some time ago but did not publish until now due to a filing mishap. Getting back on track, we have also published 2 translations of interpretations released in June 2006. Their descriptors and links appear below.

These are additions to our set of 1,796 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 1/3 years of releases of such items 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
2011-05-20 9 May 2011 External T.I. 2010-0384711E5 F - Avantages imposables Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii) ATV allowance for foreman’s supervisory use was taxable
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) allowance for gasoline expenses of forestry tree trimmers were taxable – limited exception for non-receipted reimbursement of safety equipment
2010-03-12 4 March 2010 External T.I. 2009-0348411E5 F - Bâtiment non-résidentiel admissible Income Tax Regulations - Regulation 1101 - Subsection 1101(5b.1) separate classes and separate letter elections for separate additions to the same non-eligible non-residential building
2009-08-07 29 July 2009 External T.I. 2009-0314611E5 F - Résidence pour membres du clergé à la retraite Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(c) provision of manse to retired Minister is not taxable employment benefit – so that no s. 8(1)(c) deduction
2008-11-07 3 November 2008 Internal T.I. 2008-0285781I7 F - Résidence principale Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(b) business use of residence was not “ancillary”
2007-11-02 16 October 2007 Internal T.I. 2007-0253161I7 F - Revenu d'intérêts réputés Income Tax Act - Section 17 - Subsection 17(1) “amount owing” [“créance"] refers to current rather than original balance
2007-09-28 11 September 2007 External T.I. 2006-0195851E5 F - Crédit pour impôt étranger Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax if Romania denies refund of withholding tax improperly held on management fees, CRA nonetheless will deny FTC
Treaties - Income Tax Conventions - Article 7 reasonable management fees come within the business profits rather than other income Article
2007-06-08 24 May 2007 Internal T.I. 2007-0235681I7 F - Frais de bureau à domicile Income Tax Act - Section 18 - Subsection 18(12) home office expenses to earn income from property are not subject to s. 18(12)
2006-11-03 31 October 2006 External T.I. 2006-0173731E5 F - Paragraphe 20(3) de la Loi Income Tax Act - Section 20 - Subsection 20(3) application of s. 20(3) where bank borrowing is used to repay a NIB loan used for business purposes
2006-06-30 21 February 2006 Internal T.I. 2006-0169341I7 F - Montants reçus sous le programme "Devenir" Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) amounts received by those in need as supplementary amounts to cover additional guidance costs, including reimbursement of transportation costs, were social assistance
2006-06-23 21 June 2006 External T.I. 2006-0170311E5 F - Revenu d'une SEC - Indien inscrit Other Legislation/Constitution - Federal - Indian Act - Section 87 location of business activities and customers most relevant to situs of business income from partnership with status Indian partners except where the partnership has an investing business