We have translated 6 more CRA interpretations
20 February 2023 - 11:20pm
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 2,382 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 |
|---|---|---|---|
| 2003-10-17 | 25 September 2003 External T.I. 2002-0180905 F - Cessation de résidence-Conséquences fiscales
Also released under document number 2002-01809050.
|
Income Tax Act - Section 128.1 - Subsection 128.1(4) - Paragraph 128.1(4)(b) | overview of consequences of emigration to Switzerland |
| 3 October 2003 External T.I. 2003-0004575 F - ASSURANCE-INVALIDITE
Also released under document number 2003-00045750.
|
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | premiums paid by corporation for disability policy on shareholder-employee are non-deductible | |
| Income Tax Act - Section 3 - Paragraph 3(a) | disability benefits received by corporation for disability policy on shareholder-employee are not income | ||
| 3 October 2003 External T.I. 2003-0028385 F - EXONERATION DU REVENU IMPOSABLE
Also released under document number 2003-00283850.
|
Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(d.3) | non-share corporations do not have shares | |
| 6 October 2003 External T.I. 2003-0040145 F - TRANSFERT D'UNE POLICE D'ASSURANCE-VIE
Also released under document number 2003-00401450.
|
Income Tax Act - Section 148 - Subsection 148(7) | loss on transfer of universal life policy to wholly-owned subsidiary not recognized | |
| Income Tax Act - Section 148 - Subsection 148(9) - Adjusted Cost Basis - Element A | no taxable benefit when life insurance policy transferred to wholly-owned corporation at less than its FMV | ||
| Income Tax Act - Section 246 - Subsection 246(1) | no taxable benefit when life insurance policy transferred to wholly-owned corporation at less than its FMV | ||
| 3 October 2003 External T.I. 2003-0030585 F - PENSIONS ETRANGERES
Also released under document number 2003-00305850.
|
Treaties - Income Tax Conventions - Article 18 | degree of exemption for social security pension payments from Germany, Belgium or France | |
| 2 October 2003 External T.I. 2003-0033415 F - FRAIS D'ACCES INTERNET
Also released under document number 2003-00334150.
|
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | reimbursement of high-speed internet access fees to employees who must work from home likely not a taxable benefit |