We have translated 8 more CRA interpretations

24 May 2022 - 12:20am
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We have published a further 8 translations of CRA interpretation released in December of 2004. Their descriptors and links appear below.

These are additions to our set of 2,047 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
2004-12-17 1 December 2004 Internal T.I. 2004-0065131I7 F - Sécurité sociale des États-Unis Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) US disability benefits under the US Social Security Act converted at age 62 to retirement benefits are includible under s. 56(1)(a)(i)
17 November 2004 External T.I. 2004-0067981E5 F - Fiducie de fonds commun de placement Income Tax Act - Section 132.11 - Subsection 132.11(6) s. 132.11(6) income must be pushed out to the unitholders in order to generate a s. 132.11(7) deduction
10 December 2004 Internal T.I. 2004-0082341I7 F - Dissolution d'un syndicat Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(j) liquidating distribution to union members required to be allocated first to taxable refund of dues, and balance to proceeds of disposition of their memberships
Income Tax Act - Section 54 - Capital Property liquidating distribution to union members gave rise to capital gain
2 December 2004 External T.I. 2004-0083931E5 F - Frais relatifs à une garantie prolongée Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) cost of extended car warranty that meets the s. 8(1)(f) or (h.1) conditions is deductible on cash basis
Income Tax Act - Section 18 - Subsection 18(9) cost of extended car warranty is subject to s. 18(9)
3 December 2004 External T.I. 2004-0089341E5 F - Intérêts et frais juridiques Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) interest on amount held in court until judgment rendered was contingent, and non-includible, until judgment rendered
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees legal fees to recovery a legacy were non-deductible
9 December 2004 External T.I. 2004-0093621E5 F - REÉR et faillite Income Tax Act - Section 146 - Subsection 146(8) income inclusion to bankrupt once the RRSP fund is seized by creditor after court ruling
7 December 2004 External T.I. 2004-0103061E5 F - Non Arm's Length Sale of Shares-Surpl. Stripping Income Tax Act - Section 84.1 - Subsection 84.1(1) application of s. 84.1 if company sold to accommodation party, followed by wind-up of that company and payment of purchase price
Income Tax Act - Section 245 - Subsection 245(4) scheme of Act requires that a corporate distribution be treated as income, regardless of form
7 December 2004 External T.I. 2004-0104321E5 F - Non Arm's Length Sale of Shares Income Tax Act - Section 84.1 - Subsection 84.1(2) - Paragraph 84.1(2)(b) s. 84.1(2)(b) inapplicable where member of control group of Aco sells Aco shares to Bco of which he does not own shares