We have translated 6 more CRA interpretations

We have published a further 6 translations of CRA interpretations released in November of 2003. Their descriptors and links appear below.

These are additions to our set of 2,318 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
2003-11-21 12 November 2003 External T.I. 2003-0020275 F - RECOMPENSES
Also released under document number 2003-00202750.

Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) $500 gift policy might apply to points awards if redeemable for very limited range of goods/ policy does not apply to sales awards etc.
13 November 2003 Internal T.I. 2003-0039637 F - perte sur creance et frais
Also released under document number 2003-00396370.

Income Tax Act - Section 50 - Subsection 50(1) - Paragraph 50(1)(a) capital loss under s. 50(1)(a) if deferred proceeds became uncollectible
Income Tax Act - Section 54 - Adjusted Cost Base legal fees to recover deferred proceeds of share disposition do not increase the shares’ ACB
2003-11-14 30 October 2003 External T.I. 2003-0037075 F - Associated Corporation and 129(6)
Also released under document number 2003-00370750.

Income Tax Act - Section 256 - Subsection 256(2) corporations associated through s. 256(2) continued as associated for s. 129(6) purposes where the 3rd corporation filed s. 256(2) election not to be associated with either
6 November 2003 External T.I. 2003-0039525 F - Canadian Renewable & Conservation Expenses
Also released under document number 2003-00395250.

Income Tax Regulations - Regulation 1219 - Subsection 1219(1) CCA is not an outlay or expense, and cannot qualify as CRCE
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(a) CCA is not an expense incurred
Income Tax Regulations - Schedules - Schedule II - Class 43.1 - Paragraph (d) - Subparagraph (d)(viii) computers used in operating landfill biogas site might be Class 10 property, and applications software would be Class 43.1 or Class 12 property/ below-surface pipes would not qualify
Income Tax Regulations - Schedules - Schedule II - Class 12 - Paragraph 12(o) applications software used by computers for operation of biogas landfill site would be Class 43.1 or Class 12 property
6 November 2003 External T.I. 2003-0041355 F - Subsections 110.(19) and 85(1)
Also released under document number 2003-00413550.

Income Tax Act - Section 85 - Subsection 85(1) s. 85(1) rollover for stepped-up s. 110.6(19) ACB
5 November 2003 External T.I. 2003-0045085 F - Section 159-Payments on Behalf of Others159(2)
Also released under document number 2003-00450850.

Income Tax Act - Section 159 - Subsection 159(2) trustee in bankruptcy must be acting in that capacity for that exception to apply