We have translated 8 more CRA interpretations

5 July 2022 - 12:06am
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We have published a further 8 translations of CRA interpretations released in October of 2004. Their descriptors and links appear below.

These are additions to our set of 2,125 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 ¾ 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
2004-10-22 23 September 2004 External T.I. 2004-0088801E5 F - Stop-Loss Provisions -- Grandfathering Income Tax Act - Section 248 - Subsection 248(5) - Paragraph 248(5)(b) s. 248(5)(b) does not deem the substituted shares to have been owned for so long as were the underlying shares
Income Tax Act - Section 112 - Subsection 112(3.2) s. 248(5)(b) did not deem stock dividend shares to be the same shares as those on which the dividend was paid for transitional relief purposes
19 October 2004 External T.I. 2004-0085561E5 F - Régime de droit à la plus-value des actions Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement right under phantom plan to receive the appreciation, on employment termination, as an annuity could engage the SDA rules
29 September 2004 External T.I. 2004-0092261E5 F - Acquisition of control Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(d) s. 256(7)(d) applied where two individuals transferred their equal shareholdings of Opco to a joint Holdco
Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(a) - Subparagraph 256(7)(a)(i) - Clause 256(7)(a)(i)(A) no acquisition of control where the two equal shareholders of Opco transfer their respective shareholdings to respective holding companies
8 October 2004 APFF Roundtable Q. 5, 2004-0089141C6 F - Compte de dividendes en capital Income Tax Act - Section 148 - Subsection 148(9) - Adjusted Cost Basis - Element E ACB of policy immediately before death reduced by policy loan
Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) amount net of policy loan added to CDA
2004-10-15 27 September 2004 External T.I. 2004-0067721E5 F - Frais de garde d'enfants Income Tax Act - Section 63 - Subsection 63(3) - Child Care Expense - Paragraph (d) presumption that expenses incurred prior to kindergarten age are not educational
5 October 2004 External T.I. 2004-0067741E5 F - Indemnités aux jurés Income Tax Act - Section 3 - Paragraph 3(a) juror and witness compensation includible in income - but not allowances to cover reasonable expenses
12 October 2004 External T.I. 2004-0086331E5 F - Allocation de retraite Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance instalments paid to terminated employee will be treated as s. 5 income if they are treated as employment income for CPP/EI purposes or as eligible for pension plan service years
14 October 2004 External T.I. 2004-0089921E5 F - Disposition d'une police d'assurance-vie Income Tax Act - Section 148 - Subsection 148(9) - Adjusted Cost Basis - Element L deduction of net cost of pure insurance effectively renders return of premiums partially taxable