We have translated 8 more CRA interpretations
2 May 2022 - 11:15pm
Email this ContentWe have published a further 8 translations of CRA interpretation released in January of 2005. Their descriptors and links appear below.
These are additions to our set of 2,022 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 1/3 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 |
|---|---|---|---|
| 2005-01-28 | 5 January 2005 External T.I. 2004-0085571E5 F - Art. XXIV de la Convention Canada-France | Treaties - Income Tax Conventions - Article 25 | Art. 24(1) of Canada-France Convention would provide the principal residence exemption to a Canadian citizen if France accorded the exemption to a French national residing in Canada |
| 6 January 2005 External T.I. 2004-0088791E5 F - Paragraphe 4803(2) du Règlement | Income Tax Regulations - Regulation 4803 - Subsection 4803(2) | Reg. 4803(2) satisfied if any of its paragraphs is satisfied | |
| 2005-01-21 | 19 January 2005 External T.I. 2004-0091601E5 F - Incitatif versé - taux d'intérêt réduit | Income Tax Act - Section 53 - Subsection 53(2.1) | ss. 13(7.4) and 53(2.1) elections unavailable re acquired rental property for cashback received from mortgage lender to offset high interest rate |
| Income Tax Act - Section 12 - Subsection 12(2.2) | s. 12(2.2) election available to reduce mortgage interest, re cashback received from mortgage lender, to reduce extra interest incurred in two initial years | ||
| Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(v) | s. 12(1)(x) applies (subject to s. 12(2.2) election) to lump-sum mortgage interest rebate except to the extent the amount was reported as s. 9 income | ||
| 11 January 2005 External T.I. 2004-0091981E5 F - Revenu de placements:Indiens inscrits | Other Legislation/Constitution - Federal - Indian Act - Section 87 | interest income of status Indians on loans to on-reserve businesses carrying on their business activities off-reserve were not exempted | |
| 10 January 2005 Internal T.I. 2004-0091251I7 F - Définition d'automobile | Income Tax Act - Section 248 - Subsection 248(1) - Automobile - Paragraph (e) - Subparagraph (e)(iii) | exclusion applies even where the occupant is self-employed rather than an employee of the business that owns (or leases) the truck | |
| 2005-01-14 | 13 January 2005 External T.I. 2004-0097911E5 F - Crédit d'impôt pour études | Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program | education credit unavailable where the course consisted of discrete 4-day sessions separated by a month or more – but tuition credit may be available |
| 13 January 2005 External T.I. 2004-0101701E5 F - Bien substitué | Income Tax Act - Section 248 - Subsection 248(5) - Paragraph 248(5)(b) | substituted property definition in s. 248(5)(b) does not apply for the purposes of s. 7(1.1) | |
| Statutory Interpretation - Interpretation/Definition Provisions | deeming provision only engaged when the referenced term is used | ||
| Income Tax Act - Section 7 - Subsection 7(1.1) | s. 248(5)(b) inapplicable to s. 7(1.1) | ||
| 13 January 2005 External T.I. 2004-0103281E5 F - dons et avantages | Income Tax Act - Section 248 - Subsection 248(32) | value of advantage should be based on FMV and ignore sales tax and tips |