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|