We have translated 6 more CRA interpretations

31 October 2022 - 11:14pm
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We have published translations of two interpretations released by CRA last week and a further 4 translations of CRA interpretations released in January of 2004. Their descriptors and links appear below.

These are additions to our set of 2,263 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 ¾ 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
2022-10-26 5 August 2022 External T.I. 2021-0877051E5 F - TOSI and excluded amount Income Tax Act - Section 120.4 - Subsection 120.4(1) - Excluded Shares - Paragraph (c) test not satisfied due to interest from company employing a sibling
Income Tax Act - Section 120.4 - Subsection 120.4(1) - Related Business 2nd generation income not derived from business/ interest received from company employing sibling a related business/ ownership test in (c) may be satisfied through a family trust
10 January 2022 External T.I. 2020-0873921E5 F - SUCL- Assurance responsabilité civile Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Rent Expense - Variable A - Paragraph (b) - Subparagraph (b)(ii) qualifying rent expense did not include third-party liability insurance premiums
2004-01-30 7 January 2004 External T.I. 2003-0032501E5 F - Transitional Rules/Allègement transitoire Income Tax Act - Section 112 - Subsection 112(3) CCRA adopts the order of disposition of shares chosen by the taxpayer in applying the grandfathering rules under ss. 112(3) and (3.2)
General Concepts - Transitional Provisions and Policies taxpayer could choose whether a disposition came out of a pool of grandfathered or non-grandfathered shares
22 January 2004 Internal T.I. 2003-0047561I7 F - Effet de la délégation puis de la subrogation Income Tax Act - Section 42 payment under covenant of vendor regarding mortgage assumed by purchaser, who defaulted on its assumed obligation, did not generate a s. 42 loss
Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) s. 40(2)(g)(ii) did not apply to a debt claim acquired by subrogation against a defaulted debtor since the claim was interest-bearing
28 January 2004 Internal T.I. 2003-0047701I7 F - Télétravail et indien inscrit Other Legislation/Constitution - Federal - Indian Act - Section 87 Indian teleworker exempted re duties performed on Reserve
22 January 2004 Internal T.I. 2003-0052121I7 F - Régime d'éducation permanente - période de rembour Income Tax Act - Section 146.02 - Subsection 146.02(1) - Repayment Period actual date of repayment is not taken into account