We have translated 8 more CRA interpretations

29 August 2022 - 10:31pm
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We have published a further 8 translations of CRA interpretations released in May of 2004. Their descriptors and links appear below.

These are additions to our set of 2,191 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 ¼ 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
2004-05-28 25 May 2004 External T.I. 2003-0051291E5 F - Formation et croisière Income Tax Act - Section 20 - Subsection 20(10) costs of cruise, if not viewed as training, would be non-deductible as they were incurred outside Canada
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Know-How and Training deducible cost of cruise that included seminars would not exceed the cost of a comparable domestic course
2004-05-21 18 May 2004 External T.I. 2004-0069691E5 F - Incorporation des professionnels Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(a) - Subparagraph 40(2)(a)(ii) only s. 40(2)(a)(ii)(A), not (B) or (C), is potentially engaged where transferor is individual
Income Tax Act - Section 249.1 - Subsection 249.1(2) s. 249.1(2) not engaged by virtue only of no income being allocated to the partner
Income Tax Act - Section 98 - Subsection 98(3) - Paragraph 98(3)(b) WIP subject to s. 34 election is tranferred at nil
Income Tax Act - Section 34 insolvency practice carried on by accountants does not qualify as accountancy
12 May 2004 External T.I. 2004-0072951E5 F - Ristournes versées dans un REÉR Income Tax Act - Section 135 - Subsection 135(3) no 15% withholding where patronage dividend paid to RRSP or other exempt
13 May 2004 External T.I. 2003-0051951E5 F - Course automobile amateur Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit if amateur car racing had a personal element, it should be determined whether it was carried on in a sufficiently commercial manner to be a business source
2004-05-14 11 May 2004 External T.I. 2004-0069521E5 F - Don de biens culturels Income Tax Act - Section 248 - Subsection 248(32) s. 248(32) inapplicable where contract of sale rather than deed of gift
Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Cultural Gifts - Paragraph (a) no donation of an object where donation of an interest therein
28 April 2004 Internal T.I. 2004-0071191I7 F - À quoi se rattache l'élément contrôle/propriété? Income Tax Act - 101-110 - Section 104 - Subsection 104(1) ownership or control test relates to all the listed persons
2004-05-07 30 April 2004 External T.I. 2003-0045851E5 F - L'affaire Gillette Canada inc. Income Tax Act - Section 15 - Subsection 15(2) CRA does not follow Gillette Canada
3 May 2004 External T.I. 2003-0049061E5 F - Calcul du PBR d'une terre agricole Income Tax Act - Section 43 - Subsection 43(1) allocation by sq. m. not always appropriate