We have translated 8 more CRA interpretations

12 September 2022 - 9:37pm
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We have published 8 translations of CRA interpretations released in April and March of 2004. Their descriptors and links appear below.

These are additions to our set of 2,208 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 ½ 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
2004-04-23 19 April 2004 External T.I. 2004-0063851E5 F - Année d'imposition du revenu d'entreprise Income Tax Act - Section 249.1 - Subsection 249.1(4) s. 249.1(1)(b) requires inclusion of partnership income in current calendar year where it ceases to carry on business in the year
2004-04-16 13 April 2004 External T.I. 2003-0052291E5 F - Participation exclue - Par. 40(3.15) de la Loi Income Tax Act - Section 40 - Subsection 40(3.15) “exempt interest” status not lost if the partnership property becomes a source of property rather than active business income
6 April 2004 Internal T.I. 2004-0067761I7 F - Indemnisation pour perte dans un REÉR Income Tax Act - Section 146 - Subsection 146(8) damages received by the annuitant but promptly on-paid to the RRSP do not constitute a premium or benefit
2004-04-09 5 April 2004 External T.I. 2003-0034061E5 F - Frais relatifs aux études payés par l'employeur Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) “allowance” received based on an estimate of costs incurred by employee for employer-desired master's degree would not be taxable
5 April 2004 External T.I. 2003-0050331E5 F - Allocations vestimentaires/Policiers Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) civvy clothing allowances received by police officers likely were taxable
2004-04-02 26 March 2004 Internal T.I. 2004-0060361I7 F - Date d'exécution Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day a request for support reinstatement that was styled by the court as a motion to establish support triggered a "commencement day”
30 March 2004 Internal T.I. 2004-0062711I7 F - tenure à bail Income Tax Regulations - Schedules - Schedule III - Section 4 not possible to extend the depreciation period
2004-03-26 23 March 2004 External T.I. 2003-0049031E5 F - Paragraphe 15(2) de la Loi et "montant remis" Income Tax Act - Section 15 - Subsection 15(2) loan that was anticipated to be forgiven was not a bona fide loan, so that s. 15(2) did not apply
Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract loan that was anticipated to be forgiven was not in fact a loan
Income Tax Act - Section 15 - Subsection 15(1.21) inclusion under s. 56(2) avoided second inclusion under s. 15(1.21)
Income Tax Act - Section 80 - Subsection 80(1) - Excluded Obligation loan included in income under s. 15(2) was excluded obligation re its subsequent forgiveness