We have translated over 1800 CRA interpretations

15 November 2021 - 10:35pm
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We have published a further 10 translations of CRA interpretation released in June 2006. Their descriptors and links appear below.

These are additions to our set of 1,806 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
2006-06-23 25 April 2006 External T.I. 2005-0154931E5 F - Action - société agricole familiale Income Tax Act - Section 70 - Subsection 70(10) - Share of the Capital Stock of a Family Farm or Fishing Corporation - Paragraph (a) activities of a farm partnership are attributed to those of its two corporate partners for purposes of the test
12 June 2006 Internal T.I. 2006-0186041I7 F - Résidence des membres du clergé Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(c) Roman Catholic pastoral care worker did not qualify as he could not perform most sacraments
2006-06-09 27 November 2003 Internal T.I. 2002-01805870 F - Mauvaise créance et taxes de vente Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(i) no bad debt deduction for write off of GST/QST
Excise Tax Act - Section 224 remittance of tax by supplier results in subrogation of the Crown’s claim for the tax
Income Tax Act - Section 248 - Subsection 248(16) bad debt credit is not an ITC
29 May 2006 Internal T.I. 2006-0171931I7 F - Medical expense tax credit - XXXXXXXXXX Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts “donation” to medical clinic which treated taxpayer’s son did not qualify as a charitable gift
Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(a) “donation” to clinic recharacterized as an eligible medical expense
2 June 2006 External T.I. 2006-0174671E5 F - Frais de repas et de logement Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(g) transporting of waste was not the employer’s principal business
30 May 2006 Internal T.I. 2006-0175401I7 F - Assurance-vie donnée en garantie Income Tax Act - Section 15 - Subsection 15(1) shareholder benefit where corporate universal life policy is pledged for shareholder loan, with loan plus accumulated interest repaid with cash surrender value of policy on the shareholder’s death
Income Tax Act - Section 148 - Subsection 148(9) - Proceeds of Disposition - Paragraph (b) use of policy to secure shareholder loan is not a policy loan
2006-06-02 16 May 2006 External T.I. 2005-0155251E5 F - Dépenses de vêtements - travailleur indépendant Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) CCA cannot be claimed for suits of business person
18 May 2006 Internal T.I. 2005-0162821I7 F - Imposition - article 1619 du Code civil Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) additional indemnity awarded under CCQ Art. 1619, computed by applying an interest rate to damages award, was interest
29 May 2006 External T.I. 2006-0167031E5 F - Location automobile Income Tax Act - Section 6 - Subsection 6(2) - Element E deposit that is unconditionally refundable at conclusion of the car lease does not affect the standby charge
31 May 2006 External T.I. 2006-0185481E5 F - Remboursement de dépenses et allocations Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii) premiums to cover additional personal costs of travel do not come within the s. 6(1)(b)(vii) exception