Our translations of CRA interpretations go back more than 17 years

4 April 2022 - 10:52pm
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We have published a further 8 translations of CRA interpretation released in April and March, 2005. Their descriptors and links appear below.

These are additions to our set of 1,985 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 17 years of releases of such items by the Directorate. These translations are subject to our paywall (applicable after the 5th of each month).

Bundle Date Translated severed letter Summaries under Summary descriptor
2005-04-01 23 March 2005 Internal T.I. 2005-0113931I7 F - Safe income on hand calculation: Life Insurance Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) non-deductible life insurance premiums reduced SIOH
2005-03-25 22 March 2005 External T.I. 2005-0112081E5 F - Convention de retraite - lettre de crédit Income Tax Act - Section 207.7 - Subsection 207.7(2) where LC used to secure RCA benefits and refundable tax generated on funding of LC fees, refundable tax not recoverable based on paying the benefits
Income Tax Act - Section 207.5 - Subsection 207.5(1) - Refundable Tax use of letter of credit to secure RCA benefits
Income Tax Act - Section 207.5 - Subsection 207.5(2) election not available to custodian holding an LC
22 March 2005 Internal T.I. 2005-0115451I7 F - Extinction d'une remise de dette Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount no deduction where forgiven debt is subsequently restored pursuant to improved fortunes clause
Income Tax Act - Section 80.01 - Subsection 80.01(10) repayment deduction under s. 80.01(10)
General Concepts - Effective Date CRA assesses based on the state of affairs at year end
2005-03-18 1 February 2005 External T.I. 2004-0083921E5 F - Société mandataire, gain & CIÉ Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax US taxes paid by a corporation based on falsely representing that the related gain was its gain could generate a FTC to the Canadian shareholder for which it in fact was agent
4 February 2005 External T.I. 2004-0085361E5 F - Changement de résidence: émigration Income Tax Act - Section 122.6 - Eligible Individual - Paragraph (c) required repayment of CCB if received after departure from Canada
31 January 2005 External T.I. 2004-0091301E5 F - Déductions à la source-avantage autre qu'en argent Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) no source deductions required where a non-cash benefit is the sole remuneration
Income Tax Act - Section 153 - Subsection 153(1.1) no source deductions required where free accommodation was the intern's only benefit
4 February 2005 External T.I. 2004-0093611E5 F - Don par testament d'un bien culturel Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) - Subparagraph 39(1)(a)(i.1) - Clause 39(1)(a)(i.1)(B) s. 39(1)(a)(i.1) unavailable where capital gain realized under s. 104(4)follow-up in 2005-0131741E5 F
15 March 2005 Internal T.I. 2004-0108721I7 F - Don d'une licence Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts gift of a non-exclusive software licence was a gift of property
Income Tax Act - Section 248 - Subsection 248(1) - Property excepting WIP, definition of property is no broader than term’s ordinary meaning