We have translated 7 more CRA severed letters
We have published a translation of a ruling released by CRA two months ago and of two interpretations released by CRA two weeks ago, and a further 4 translations of CRA interpretations released in December and November of 2003. Their descriptors and links appear below.
These are additions to our set of 2,312 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 19 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|
|2022-12-21||7 December 2022 External T.I. 2020-0846891E5 F - SSUC - Revenu admissible
2021-0878941E5 F is similar
|Income Tax Act - Section 125.7 - Subsection 125.7(7)||limited partner’s share of LP revenues cannot be qualifying revenue|
|12 December 2022 External T.I. 2021-0878941E5 F - SSUC - Revenu admissible
2020-0846891E5 F is similar
|Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Revenue||partner’s share of qualifying revenue is not qualifying revenue|
|2022-10-26||2021 Ruling 2021-0877011R3 - Post-mortem Hybrid Pipeline||Income Tax Act - Section 84 - Subsection 84(2)||note issued on post-mortem pipeline effected on portfolio company paid off over 3 years commencing 1 year after transfer by estate to Newco|
|2003-12-05||14 November 2003 External T.I. 2003-0013445 F - Application de 94(1) et 128.1(1)
Also released under document number 2003-00134450.
|Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(a)||application of s. 94 subject to prior to application of s. 128.1(a)(a)|
|29 September 2003 External T.I. 2003-0013435 F - Pension Belge
Also released under document number 2003-00134350.
|Treaties - Income Tax Conventions - Article 18||Belgian National Pensions Office was a Belgian government instrumentality for purposes of the former Art. 18(2) exemption|
|2003-11-28||19 November 2003 Internal T.I. 2003-0047687 F - Interest Calculation T/P Adjustment RQST
Also released under document number 2003-00476870.
|Income Tax Act - Section 161 - Subsection 161(7) - Paragraph 161(7)(a) - Subparagraph 161(7)(a)(iv)||substitution of NCL carrybacks with CCA claims for nil assessment taxation years does not generate s. 161(1) interest|
|Income Tax Act - Section 161 - Subsection 161(1)||substitution of NCL carrybacks with CCA claims for nil assessment taxation years does not generate s. 161(1) interest|
|18 November 2003 External T.I. 2003-0181195 F - REGLEMENT STRUCTURE
Also released under document number 2003-01811950.
|Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(d)||CCRA position on exemption of structured settlements (as described) extends to court-ordered personal injury payments|
|Income Tax Act - Section 3 - Paragraph 3(a)||summary of CCRA position on structured settlements|