We have translated over 2,000 CRA interpretations

18 April 2022 - 10:50pm
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We have published a further 8 translations of CRA interpretation released in February, 2005. Their descriptors and links appear below.

These are additions to our set of 2,004 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
2005-02-18 16 February 2005 External T.I. 2004-0097161E5 F - Fin d'exercice d'une société de personnes Income Tax Act - Section 249.1 - Subsection 249.1(4) - Paragraph 249.1(4)(b) requirement that there not be a multi-tier partnership must be satisfied each fiscal period
8 February 2005 Internal T.I. 2004-0099681I7 F - Remboursement de frais de déménagement Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) reimbursement of reasonable living expenses incurred until the employee permanently occupies new home in employer’s area is not a benefit
16 February 2005 Internal T.I. 2004-0105401I7 F - Frais de publicité Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose costs of commenting on an issue unrelated to the business were non-deductible
17 September 1998 External T.I. 98222950 F - Régime d'accession à la propriété - habitation admissible Income Tax Act - Section 146.01 - Subsection 146.01(1) - Qualifying Home qualifying home can be part of a larger commercial buildingAlso referred to as 9822295
17 February 2005 External T.I. 2004-0090411E5 F - Bien de remplacement-dispos. involontaire Income Tax Act - Section 44 - Subsection 44(5) - Paragraph 44(5)(a.1) replacement property potentially can be held through a partnership if the partnership property is physically similar
Income Tax Act - Section 13 - Subsection 13(4) rollover not available where building replaced by interest in partnership carrying on a similar business because the partnership interest is not depreciable property
2005-02-11 2 February 2005 External T.I. 2004-0104671E5 F - Convention de retraite - Fonds mis de côté Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement amounts agreed to be paid post-retirement do not create an SDA if they are not reasonably regarded as deferred salary
Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement no requirement that payment to the other be in trust
3 February 2005 External T.I. 2005-0111871E5 F - Intérêts / mise à part de l'argent Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) cash damming to pay current deductible business expenses is an eligible use which continues with the business
3 February 2005 External T.I. 2005-0112141E5 F - Safe income Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) safe income prorated on a partial crystallization of an accrued gain