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 2,324 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
2003-11-14 3 November 2003 Internal T.I. 2003-0044817 F - Copies of Electronic Documents
Also released under document number 2003-00448170.

Income Tax Act - Section 231.1 - Subsection 231.1(1) CCRA auditors may take electronic copies of taxpayer records
Income Tax Act - Section 231.5 - Subsection 231.5(1) CCRA audit right to take electronic copies and to print out
5 November 2003 Internal T.I. 2003-0036737 F - BOURSES D'ETUDES
Also released under document number 2003-00367370.

Income Tax Act - Section 56 - Subsection 56(3) $3,000 exemption unavailable where education tax credit not available in the same taxation year
5 November 2003 Internal T.I. 2003-0043277 F - Benefit-Use of Automobiles
Also released under document number 2003-00432770.

Income Tax Act - Section 246 - Subsection 246(1) - Paragraph 246(1)(a) s. 246(1)(a) application re mother’s use of a car of Opco controlled by her son’s Holdco to her rather than son turned on whether her minority Holdco had significant influence over Opco
Income Tax Act - Section 15 - Subsection 15(5) application of s. 15(5) to shareholder’s use of company automobile
Income Tax Act - Section 10 - Subsection 10(1) automobiles in car dealer inventory used for employee’s personal use remained in inventory, cf. if converted primarily to personal use of shareholder (which would not be a disposition)
Income Tax Act - Section 9 - Computation of Profit conversion of automobile in car inventory to personal use of CEO would not entail its deemed disposition nor would the conversion of car inventory to personal use of shareholders
2003-11-07 30 October 2003 External T.I. 2003-0037465 F - Subsections 40(3.3) & 40(3.4)
Also released under document number 2003-00374650.

Income Tax Act - Section 40 - Subsection 40(3.4) non-application of s. 40(3.4) where taxpayer acquires then immediately disposes of an additional block/ application of formula where it partially dips into existing block
4 November 2003 External T.I. 2003-0042295 F - CONVENTION DE RETRAITE REVENU D'INTERET
Also released under document number 2003-00422950.

Income Tax Act - Section 207.5 - Subsection 207.5(1) - Refundable Tax - Paragraph (b) requirement to include interest income under s. 12 in computing refundable tax at end of year
31 October 2003 External T.I. 2003-0045795 F - DEDOMMAGEMENT POUR PERTE DE REVENU
Also released under document number 2003-00457950.

Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) Quebec government compensation to pension plan members for cessation of employer contributions was not itself pension or other income
Income Tax Act - Section 3 - Paragraph 3(a) lump sum government compensation for loss of employer pension plan contributions was not income from a source