We have translated 8 more CRA interpretations

8 August 2022 - 11:46pm
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We have published a further 8 translations of CRA interpretations released in July and June of 2004. Their descriptors and links appear below.

These are additions to our set of 2,167 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
2004-07-02 24 June 2004 Internal T.I. 2004-0065301I7 F - Frais médicaux - purificateur d'air Income Tax Regulations - Regulation 5700 - Section 5700 - Paragraph 5700(c.1) air exchanger can also serve as air purifier/ “severe” excludes seasonal allergies
2004-06-25 17 June 2004 External T.I. 2003-0045411E5 F - Entreprise de placement déterminée Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) business carried on through partnership is separate from similar business carried on directly by partner
Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business - Paragraph (b) para. (b) may not apply where the SIB is carried on through a partnership
Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business - Paragraph (a) partnership business is transparent but separate from similar business carried on directly
18 June 2004 External T.I. 2004-0058621E5 F - Société agricole familiale Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Share of the Capital Stock of a Family Farm or Fishing Corporation shares did not qualify where 24-month holding period not satisfied after s. 85(1) roll in of farming business
22 June 2004 External T.I. 2004-0060211E5 F - Allocation pour utilisation d'un véhicule à moteur Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) travel from home to numerous different customer locations was not personal
21 June 2004 External T.I. 2004-0074851E5 F - Allocation de retraite Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance severance was a retiring allowance even though the employee was hired by another municipality that had agreed to take over the municipal functions of her first employer
Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(c) - Subparagraph 251(2)(c)(i) two municipalities were not Crown agents or controlled by provincial government and, therefore, were not related
Income Tax Act - Section 60 - Paragraph 60(j.1) - Subparagraph 60(j.1)(ii) - Clause 60(j.1)(ii)(C) unrelated person who has assumed a severance payment obligation is treated as paying the severance on behalf of the “employer” who terminated
18 May 2004 External T.I. 2002-0168191E5 F - Somme reçue après la fin d'une succession Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) pension payment received after estate termination was included in beneficiaries’ income pursuant to s. 56(1)(a) rather than s. 104(13)
Income Tax Act - 101-110 - Section 104 - Subsection 104(13) pension payment received after estate termination bypassed the s. 104(6) and s. 104(13) system
2004-06-18 10 June 2004 Internal T.I. 2004-0073781I7 F - Orphelins et orphelines de Duplessis - intérêts Income Tax Act - Section 3 - Paragraph 3(a) interest earned on tax-free injury award was taxable
11 June 2004 External T.I. 2004-0076291E5 F - Renonciation aux intérêts à recevoir Income Tax Act - Section 12 - Subsection 12(3) renunciation of accrued interest during the year means that there is no inclusion of such interest during the year under s. 12(3) or 12(1)(c)