Our translations of CRA interpretations go back over 18 years
1 August 2022 - 11:48pm
Email this ContentWe have published a further 8 translations of CRA interpretations released in July of 2004. Their descriptors and links appear below.
These are additions to our set of 2,159 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 18 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 |
|---|---|---|---|
| 2004-07-23 | 13 July 2004 External T.I. 2004-0058141E5 F - Transfert du droit aux revenus provenant d'un bien | Income Tax Act - Section 248 - Subsection 248(3) | assignment of the rents from a rental property to a corporation would result in a disposition to a deemed trust under s. 248(3) |
| Income Tax Act - Section 85 - Subsection 85(1) | rollover not available to assignment of the rents from a rental property to a corporation for shares since the transferee was a deemed trust under s. 248(3) | ||
| Income Tax Act - Section 75 - Subsection 75(2) | s. 75(2) applicable to assignment of the rents from a rental property to a corporation giving rise to a deemed trust under s. 248(3) | ||
| 2004-07-16 | 6 July 2004 External T.I. 2004-0081631E5 F - Price Adjustment Clauses | General Concepts - Effective Date | no requirement to notify CRA of price-adjustment clause otherwise than by ticking box on any prescribed form |
| Income Tax Act - Section 51 - Subsection 51(1) | no requirement to notify CRA of price-adjustment clause regarding a s. 86 or 51 exchange | ||
| Income Tax Act - Section 85 - Subsection 85(1) | ticking "yes" box on election form is sufficient notice of price adjustment clause | ||
| 2004-07-09 | 29 June 2004 External T.I. 2004-0065941E5 F - Revenu de bien ou d'entreprise exploitée active | Income Tax Act - Section 129 - Subsection 129(6) | double application of s. 129(6) where active business sub pays interest to its Holdco parent which, in turn, pays interest to its parent |
| 24 June 2004 Internal T.I. 2004-0068381I7 F - Date d'exécution | Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day - Paragraph (b) - Subparagraph (b)(ii) | change in required support amount triggers commencement day regardless of the number of children covered by the changed support | |
| 28 June 2004 Internal T.I. 2004-0073761I7 F - Dommages-intérêts-perte d'emploi | Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | damages for failure to reinstate the taxpayer were a retiring allowance | |
| Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(l.1) | reimbursement of legal costs incurred to recover damages for failure to reinstate were includible under s. 56(1)(l.1) | ||
| Income Tax Act - Section 60 - Paragraph 60(o.1) | deduction for legal fees incurred to recover damages that were retiring allowance | ||
| Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | change regarding pre-judgment interest judicially ordered after 2003 | ||
| 29 June 2004 External T.I. 2004-0078951E5 F - Non Arm's Length Sale of Shares, Surplus Stripping | Income Tax Act - Section 84.1 - Subsection 84.1(1) | s. 84.1 could apply if unrelated purchaser is an accommodation party | |
| 29 June 2004 Internal T.I. 2004-0081901I7 F - Taxable Benefit - Life Insurance Premiums | Income Tax Act - Section 15 - Subsection 15(1) | benefit from payment by corporation of life insurance premiums on policy of which shareholder’s spouse is the beneficiary is based on the premiums so paid | |
| 2004-07-02 | 28 June 2004 External T.I. 2004-0059311E5 F - Associated Corporations | Income Tax Act - Section 256 - Subsection 256(3) - Paragraph 256(3)(a) | "controlled, directly or indirectly in any manner whatever" includes de jure control |
| Income Tax Act - Section 256 - Subsection 256(6) | where s. 256(6) applies, it excludes both de jure and de facto control by the creditor | ||
| Income Tax Act - Section 256 - Subsection 256(5.1) | the defined phrase includes de jure control |