We have translated 7 more CRA severed letters
13 February 2023 - 11:20pm
Email this ContentWe have published a translation of a ruling released by CRA 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 2,376 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 |
|---|---|---|---|
| 2023-02-08 | 2021 Ruling 2021-0887301R3 F - Post-mortem pipeline transaction | Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d.3) | application of s. 88(1)(d.3) to pipeline involving shares that had been stepped up under s. 104(4) |
| Income Tax Act - Section 84 - Subsection 84(2) | double pipeline entailing the application of s. 84.1 and s. 88(1)(d) bump | ||
| Income Tax Act - Section 84.1 - Subsection 84.1(2) - Paragraph 84.1(2)(a.1) - Subparagraph 84.1(2)(a.1)(ii) | application of ss. 84.1(1) and (2)(a.1)(ii) to transfer of shares by spousal trust that had received such shares from the testator who had stepped such shares up under s. 110.6(2.1) | ||
| 2003-10-24 | 10 October 2003 External T.I. 2003-0036865 F - TRANSFER DE POLICE D'ASSURANCE
Also released under document number 2003-00368650.
|
Income Tax Act - Section 15 - Subsection 15(1) | benefit to shareholder on gratuitous transfer to it of critical illness policy entitled to refund of premiums on maturity |
| Income Tax Act - Section 148 - Subsection 148(7) | s. 148(7) inapplicable to critical illness policy | ||
| General Concepts - Fair Market Value - Other | FMV of critical illness policy takes refundable premium amount into account | ||
| 16 October 2003 Internal T.I. 2003-0032537 F - EQUIVALENT POUR PERSONNE
Also released under document number 2003-00325370.
|
Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) | young child could not claim credit for mother | |
| 10 October 2003 External T.I. 2003-0037145 F - CONVENTION DE RETRAITE
Also released under document number 2003-00371450.
|
Income Tax Act - Section 207.6 - Subsection 207.6(2) - Paragraph 207.6(2)(d) | deemed withdrawals from RCA through payment of insurance benefits not subject to tax under para. (d) | |
| 10 October 2003 External T.I. 2003-0035385 F - POLICE D'ASSURANCE CONTRE MALADIE GRAVE
Also released under document number 2003-00353850.
|
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | premiums on critical illness policy are non-deductible to the corporate policyholder even if it is the beneficiary | |
| Income Tax Act - Section 15 - Subsection 15(1) | corporate payment of premiums on critical illness policy for its sole shareholder generated taxable benefit | ||
| 10 October 2003 External T.I. 2003-0035655 F - CBR D'UNE POLICE D'ASSURANCE TRANSFEREE
Also released under document number 2003-00356550.
|
Income Tax Act - Section 148 - Subsection 148(9) - Adjusted Cost Basis | ACB addition, for gratuitous transfer of corporation’s life insurance policy under s. 148(7) to the insured shareholder/employee, equals excess of policy ACB over its CSV | |
| Income Tax Act - Section 148 - Subsection 148(7) | consequences of gratuitous transfer of corporation’s life insurance policy under s. 148(7) to the insured shareholder/employee | ||
| 10 October 2003 External T.I. 2003-0035685 F - DEDUCTION INTERETS MONTANT RAISON
Also released under document number 2003-00356850.
|
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | reasonableness of interest rate assessed in light of comparable market rates and issue premiums |