We have translated 6 more CRA interpretations

We have published 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 2,369 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 1/3 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
2003-10-24 10 October 2003 External T.I. 2003-0037135 F - CONTRATS DE RENTE VIAGERE
Also released under document number 2003-00371350.

Income Tax Regulations - Regulation 301 - Subsection 301(1) annuity did not qualify as a "life annuity" where payments made to a corporation
15 October 2003 External T.I. 2003-0014535 F - FRAIS DE GARDE D'ENFANTS
Also released under document number 2003-00145350.

Income Tax Act - Section 63 - Subsection 63(3) - Child Care Expense - Paragraph (d) fees for daycare at day sports camp could qualify
10 October 2003 External T.I. 2003-0035645 F - DEDUCTIBILITE DES INTERETS
Also released under document number 2003-00356450.

Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) Ludco and Singleton accepted/ description of how and why cash damming works
Income Tax Act - Section 16 - Subsection 16(1) interest imputed on a non-interest-bearing note issued at a discount consists of simple interest (annually deductible) and compound interest (deductible only at maturity)
10 October 2003 External T.I. 2003-0035665 F - TRANSFER D'UNE POLICE D'ASSURANCE-VIE
Also released under document number 2003-00356650.

Income Tax Act - Section 148 - Subsection 148(7) transfer to shareholder at policy’s FMV is not a “distribution”
10 October 2003 External T.I. 2003-0035675 F - EVALUATION D'UNE POLICE D'ASSURANCE-VIE
Also released under document number 2003-00356750.

Income Tax Act - Section 70 - Subsection 70(5.3) unpaid policy loan to corporation is to be deducted in determining shares’ FMV if the accords with valuation principles
10 October 2003 External T.I. 2003-0037125 F - AVANCE SUR POLICE
Also released under document number 2003-00371250.

Income Tax Act - Section 148 - Subsection 148(9) - Policy Loan withdrawal can qualify as policy loan even if not named as such under the policy