We have translated 8 more CRA interpretations
3 October 2022 - 10:39pm
Email this ContentWe have published 8 translations of CRA interpretations released in March and February of 2004. Their descriptors and links appear below.
These are additions to our set of 2,232 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 2/3 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 |
|---|---|---|---|
| 2004-03-05 | 25 February 2004 External T.I. 2003-0042461E5 F - Invalidité d'un actionnaire/admin./employé | Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | premiums paid by corporation on disability policy on its principal employee are non-deductible |
| Income Tax Act - Section 3 - Paragraph 3(a) | disability benefits received by corporation to fund continuing salary-equivalent payments to its chief employee are not income | ||
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | taxable continued payment of salary-equivalent payments to disabled employee, but no taxable benefit from employer’s previous payment of premiums on funding disability policy | ||
| 23 February 2004 External T.I. 2003-0050641E5 F - Fiducie | Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | no particular mortality table required re donation of a residual interest in a trust to a public charitable foundation | |
| 23 February 2004 External T.I. 2003-0051371E5 F - Déduction des intérêts | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | non-deductible personal residence interest could be converted to deductible interest through sale of rental property to spouse for money borrowed by her | |
| 16 February 2004 External T.I. 2003-0054091E5 F - Rollover for Contractors | Income Tax Act - Section 85 - Subsection 85(1.1) - Paragraph 85(1.1)(a) | construction lien holdbacks are eligible property that can be transferred at a nominal agreed amount | |
| Income Tax Act - Section 56 - Subsection 56(4) | s. 56(4) not applied where construction lien holdbacks are transferred on s. 85(1) rollover basis to transferee, which includes them when they become receivable | ||
| 2 March 2004 Internal T.I. 2003-0045921I7 F - 118(5) - impact d'une clause rétroactive | Income Tax Act - Section 118 - Subsection 118(5) | homologated order with effect of judgment that retroactively eliminated Monsieur’s support obligation re one of his children did not retroactively eliminate the s. 118(5) prohibition | |
| General Concepts - Effective Date | CRA would not apply a retroactive judgment to the affected prior period because it was inconsistent with the actual understanding at the time | ||
| 23 February 2004 External T.I. 2004-0057051E5 F - RAP - Personne séparée | Income Tax Act - Section 146.01 - Subsection 146.01(1) - Regular Eligible Amount - Paragraph (f) | separated spouse’s ownership is relevant | |
| 3 March 2004 Internal T.I. 2004-0061781I7 F - Engagement de non-concurrence | Income Tax Act - Section 9 - Exempt Receipts/Business | Manrell inapplicable where recipient of non-compete carried on the related business | |
| 2004-02-27 | 24 February 2004 External T.I. 2003-0041121E5 F - Avantages imposables-installations récréatives | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | making employer’s resort recreational facilities available to all employees not a taxable benefit |