We have translated 6 more CRA interpretations
12 December 2022 - 11:13pm
Email this ContentWe have published a further 6 translations of CRA interpretations released in January of 2004. Their descriptors and links appear below.
These are additions to our set of 2,299 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 |
|---|---|---|---|
| 2004-01-09 |
16 December 2003 Internal T.I. 2003-0046167 F - Section 50- Shares of Insolvent Corporation50(1) Also released under document number 2003-00461670.
|
Income Tax Act - Section 50 - Subsection 50(1) - Paragraph 50(1)(b) - Subparagraph 50(1)(b)(iii) | corporation not insolvent if affiliates intend to pay its creditors, and its shares have value if it has non-capital losses |
| Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | sale of Lossco with no assets but non-capital losses for nil consideration to another subsidiary generated a gain under s. 69(1)(b) | ||
| General Concepts - Fair Market Value - Shares | shares of corporation that had ceased business and had no assets but had non-capital losses had a significant value | ||
|
8 December 2003 Internal T.I. 2003-0042537 F - CIEE & SRAS Also released under document number 2003-00425370.
|
Income Tax Act - Section 122.3 - Subsection 122.3(1) | lay-off due to SARS did not qualify as an absence | |
| 2004-01-02 |
22 December 2003 External T.I. 2003-0000125 F - TITRE DE CREANCE INDEXE Also released under document number 2003-00001250.
|
Income Tax Regulations - Regulation 7001 - Subsection 7001(1) | detailed illustration |
| Income Tax Act - Section 248 - Subsection 248(1) - Indexed Debt Obligation | stripped indexed coupons were indexed debt obligations but would not give rise to excluded payments | ||
| Income Tax Regulations - Regulation 7001 - Subsection 7001(7) - Excluded Payment | stripped indexed coupons did not give rise to excluded payments because no single fixed rate | ||
| Income Tax Regulations - Regulation 201 - Subsection 201(4.1) | reporting of inflation adjustments on indexed bonds | ||
| Income Tax Act - Section 20 - Subsection 20(14) | application of s. 20(14) to indexed debt obligation | ||
|
11 December 2003 External T.I. 2003-0015975 F - calcul du gain/perte sur disposition Also released under document number 2003-00159750.
|
Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | portion of share sales proceeds required under a Bankruptcy Act proposal to be paid to the unsecured creditors, not a disposition expense | |
|
16 December 2003 External T.I. 2003-0027245 F - MCIA-ACQUIS. D'UNE PERSONNE LIEE Also released under document number 2003-00272450.
|
Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital - Element A - Element A.1 | subsequent arm’s length acquisition does not vitiate application of A.1 | |
|
22 December 2003 External T.I. 2003-0053005 F - transfert d'un reer a un ferr Also released under document number 2003-00530050.
|
Income Tax Act - Section 146 - Subsection 146(16) - Paragraph 146(16)(b) | shares may not be transferred from maturing RRSP to RRIF if they will not provide the annuity to make the minimum payments |