We have translated 6 more CRA interpretations
6 February 2023 - 11:33pm
Email this ContentWe 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 |