We have translated 7 more CRA severed letters

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

These are additions to our set of 2,346 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 ¼ 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
2023-01-11 2021 Ruling 2020-0852541R3 F - Split-up XXXXXXXXXX Butterfly Income Tax Act - Section 55 - Subsection 55(1) - Distribution one-wing split-up butterfly with a preliminary cash distribution of life insurance proceeds
Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b) resolution of Part IV tax circularity issue on butterfly to be resolved by local TSO
2003-11-07 27 October 2003 Internal T.I. 2003-0022887 F - CII-PECHEURS
Also released under document number 2003-00228870.

Income Tax Act - Section 127 - Subsection 127(9) - Specified Percentage - Paragraph (a) - Subparagraph (a)(iii) Gaspé Peninsula includes St. Lawrence
29 October 2003 External T.I. 2003-0026355 F - ECHANGE D'ACTIONS
Also released under document number 2003-00263550.

Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(f) - Subparagraph 110.6(14)(f)(i) s. 110.6(14)(f)(i) applies to shares issued as part consideration for shares of a different class transferred to the corporation on a dirty s. 85 exchange
5 November 2003 Internal T.I. 2003-0037977 F - FRAIS POUR ANNULER UNE OFFRE D'ACHAT
Also released under document number 2003-00379770.

Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) legal fees incurred to defend a repudiation of a purchase contract might be a disposition expense (of the rights to purchase)
31 October 2003 Internal T.I. 2003-0040997 F - CHANTIER PARTICULIER REPAS CONJOINT
Also released under document number 2003-00409970.

Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) s. 6(6)(a) does not extend to covering meal expenses of visiting spouses
2003-10-31 29 October 2003 External T.I. 2003-0033435 F - CREDIT POUR INTERET SUR PRETS ETUDIANTS
Also released under document number 2003-00334350.

Income Tax Act - Section 118.62 exclusion for amount paid in satisfaction of a judgment applies to interest that was paid during the course of the legal proceedings resulting in the judgment
29 October 2003 External T.I. 2003-0037435 F - REMBOURSEMENT DE PAIMENTS D'UN REEE
Also released under document number 2003-00374350.

Income Tax Act - Section 146.1 - Subsection 146.1(2) subscriber can assign or pledge the right to receive repayments of payments