We have translated 7 more CRA severed letters
30 January 2023 - 10:59pm
Email this ContentWe have published a translation of a CRA ruling released last week, and a further 6 translations of CRA interpretations released in October of 2003. Their descriptors and links appear below.
These are additions to our set of 2,363 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 |
|---|---|---|---|
| 2023-01-25 | 2022 Ruling 2020-0858451R3 F - Trust to trust transfer | Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Trust - Paragraph (g) | deemed disposition under s. 104(4) avoided through irrevocable vesting of interests in successor trust |
| Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (f) | no disposition on transfer of assets of Trust 1 to Trust 2 with essentially the same terms other than a clause facilitating irrevocable-vesting designations | ||
| 2003-10-31 | 23 October 2003 External T.I. 2003-0017935 F - BIEN AGRICOLE ADMISSIBLE
Also released under document number 2003-00179350.
|
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property | rebate of municipal taxes reduces the farming expense rather than constituting gross revenue from farming |
| Income Tax Act - Section 248 - Subsection 248(1) - Gross Revenue | rebate of municipal taxes reduced that business expense rather than constituting gross revenue | ||
| Income Tax Act - Section 9 - Expense Reimbursement | reimbursement of business expense reduces the expense rather than being included in gross revenue | ||
| 15 October 2003 External T.I. 2003-0030905 F - Associated Corporations and 129(6)
Also released under document number 2003-00309050.
|
Income Tax Act - Section 256 - Subsection 256(2) | s. 256(2) election does not affect the operation of s. 129(6) | |
| 29 October 2003 External T.I. 2003-0006505 F - REGIME D'ASSURANCE SALAIRE
Also released under document number 2003-00065050.
|
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) | criteria for determining whether there are separate plans | |
| 20 October 2001 External T.I. 2003-0007015 F - RESSOURCE INTERMEDIAIRE
Also released under document number 2003-00070150.
|
Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(h) | amounts received for accommodating disabled individuals in the taxpayer’s home were exempted | |
| Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) | amounts received for accommodating disabled individuals in the taxpayer’s home would not engage s. 45(1)(c) if they were exempted under s. 81(1)(h) | ||
| 2003-10-24 | 20 October 2003 External T.I. 2003-0014615 F - allocation non-imposable
Also released under document number 2003-00146150.
|
Income Tax Act - Section 6 - Subsection 6(16) - Paragraph 6(16)(a) | per-kilometre rates published by Finance could be used for reasonableness purposes |
| 16 October 2003 External T.I. 2003-0038315 F - CONVENTION DE RETRAITE
Also released under document number 2003-00383150.
|
Income Tax Act - Section 248 - Subsection 248(1) - Retirement Compensation Arrangement | loan back to employer may negate RCA status | |
| Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | reasonableness of interest rate determined re market interest rates |