We have translated 8 more CRA interpretations

10 October 2022 - 11:51pm
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We have published 8 translations of CRA interpretations released in February of 2004. Their descriptors and links appear below.

These are additions to our set of 2,240 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
2004-02-27 20 February 2004 External T.I. 2003-0035361E5 F - Chantier particulier - travail temporaire Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) - Subparagraph 6(6)(a)(i) single 3-year term contract could be work of a temporary nature
30 January 2004 Internal T.I. 2003-0037191I7 F - Fabrication /sous-traitants/frais de gestion Income Tax Regulations - Regulation 5202 - Cost of Labour - Paragraph (a) cost of labour included amounts paid to a sister company that paid the employees on behalf of the manufacturer
Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) s. 153(1) applicable to salaries paid as agent
Income Tax Regulations - Regulation 5202 - Cost of Labour - Paragraph (b) - Subparagraph (b)(iii) tasks performed by subcontractors were not normally performed by employees
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose partial disallowance of salaries of taxpayer where it was not fully reimbursed by the recipient of their services
6 February 2004 External T.I. 2003-0044021E5 F - Les règles d'attribution et les REER Income Tax Act - Section 74.1 - Subsection 74.1(1) RRSP withdrawal of property funded with contribution by the annuitant's spouse is income to the spouse under s. 74.1(1)
23 February 2004 External T.I. 2003-0048121E5 F - Paiement reçu - annulation d'un contrat Income Tax Act - Section 9 - Capital Gain vs. Profit - Foreign Exchange surrogatum principle applied to FX hedging termination payment
24 February 2004 External T.I. 2003-0049351E5 F - Dommages moraux Income Tax Act - Section 3 - Paragraph 3(a) damages received for pain and suffering or loss of amenities of life are non-taxable
6 April 2003 External T.I. 2003-0054461E5 F - Traitement fiscal d'un cadeau Income Tax Act - Section 9 - Nature of Income “gift” may be business income to the recipient
2004-02-20 17 February 2004 Internal T.I. 2003-0046981I7 F - Paragraphe 98(5) de la Loi Income Tax Act - Section 98 - Subsection 98(5) s. 98(5) inapplicable on an amalgamation of the members
13 February 2004 External T.I. 2003-0027361E5 F - Déductibilité des intérêts -TPS et TVQ Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose interest on assessments for failure to collect or remit GST that was collectible in respect of a business or property, is deductible