Our translations of CRA Interpretations go back over 16 years

3 January 2022 - 10:50pm
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We have published a further 10 translations of CRA interpretation released in January, 2006 and December, 2005. Their descriptors and links appear below.

These are additions to our set of 1,869 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 16 years of releases of such items by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. You are curently in the "open" week for January.

Bundle Date Translated severed letter Summaries under Summary descriptor
2006-01-06 16 December 2005 External T.I. 2005-0150411E5 F - Roll-over Provisions and Partnership Income Tax Act - Section 86 - Subsection 86(1) partnership is a taxpayer for s. 51(1), 85.1(1) or 86(1) exchange purposes
Income Tax Act - Section 248 - Subsection 248(1) - Taxpayer partnership with non-resident partners is a taxpayer for s. 51(1), 85.1(1) or 86(1) rollover purposes
Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(a) partnership is taxpayer for income computation purposes even if it has non-resident partners
2005-12-09 9 November 2005 Internal T.I. 2005-0133261I7 F - Frais médicaux payés à l'avance Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(a) prepaid dental care does not qualify until the year in which the care is received
Income Tax Act - Section 118.2 - Subsection 118.2(1) - B - Paragraph (a) a receipt for prepaid medical care does not qualify
21 November 2005 External T.I. 2005-0121232E5 F - Bien agricole admissible Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property holding of property for a period by their aunt disqualified it as a QFP
8 November 2005 External T.I. 2005-0148091E5 F - Résidence principale-deux unités de condominium Income Tax Act - Section 54 - Principal Residence two stacked condos connected by an interior staircase constituted two housing units
8 November 2005 Internal T.I. 2004-0109351I7 F - Frais juridiques - pension alimentaire Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees legal expenses to obtain increased support, but not to reduce a support obligation, are currently deductible
26 October 2005 External T.I. 2005-0117551E5 F - État des loyers de biens immeubles Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense costs of disinfecting, de-odourizing and repairing a rental home were currently deductible
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) prohibition applied to travel and accommodation expenses incurred in dealing with a rental property left in substandard condition
16 November 2005 Internal T.I. 2005-0153071I7 F - Interprétation de l'alinéa 147.4(1)c) Income Tax Act - Section 147.4 - Subsection 147.4(1) further single-premium contract must be acquired for subsequent employees rather than being added with additional premium to existing contract
9 November 2005 Internal T.I. 2005-0154301I7 F - Choix concernant les immobilisations admissibles Income Tax Regulations - Schedules - Schedule II - Class 14.1 operating agreement of care facility with province was goodwill because it could not be transferred without a transfer of the care business
Income Tax Act - Section 14 - Subsection 14(1.01) cost of property acquired can be nil
8 November 2005 External T.I. 2005-0117791E5 F - Exonération des gains en capital Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (e) - Subparagraph (e)(ii) asset utilization test referred to in subpara. (e)(ii) takes into account the more stringent test in para. (d)
29 November 2005 Internal T.I. 2005-0130101I7 F - ITC - Logging Truck Income Tax Regulations - Regulation 4600 - Subsection 4600(2) - Paragraph 4600(2)(f) trucking by sub-contractor can qualify