We have translated 7 more CRA interpretations
6 March 2023 - 10:52pm
Email this ContentWe have published a CRA interpretation 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 2,397 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 |
|---|---|---|---|
| 2023-03-01 | 30 June 2022 Internal T.I. 2022-0936671I7 F - Frais de déplacement | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | one-time travel between a home office and the employer’s office was in the course of employment |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii.1) | per-kilometer allowances for one-time travel between home office and employer’s office qualified under s. 6(1)(b)(vii.1 | ||
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii) | one-time travel between home office and employer’s office did not qualify as travel away from the employer’s establishment | ||
| Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(b) | potential exclusion of allowances for meals and hotels paid for travel to a remote work site (an office) of the employer where the employees stay for 3 days | ||
| 2003-10-17 | 8 September 2003 Internal T.I. 2003-0010407 F - Gains et pertes sur change étranger
Also released under document number 2003-00104070.
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Income Tax Act - Section 39 - Subsection 39(2) | s. 39(2) applies to interest on US mortgage |
| Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | Gaynor applies in computing gain on disposition of US securities | ||
| 29 September 2003 Internal T.I. 2003-0027347 F - FRAIS MEDICAUX DEPLACEMENT
Also released under document number 2003-00273470.
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Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(h) | travel and accommodation expenses of parents in order to be near their hospitalized child were not covered | |
| 24 September 2003 Internal T.I. 2003-0184097 F - perte au titre de placement
Also released under document number 2003-01840970.
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Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | Byram accepted: NIB loan can be made with a view to dividends | |
| 2003-10-10 | 11 September 2003 Internal T.I. 2003-0026217 F - Report de Pertes du de Cujus
Also released under document number 2003-00262170.
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Income Tax Act - Section 111 - Subsection 111(2) | net capital loss in year before death could be carried back rather than applied against all income in the two s. 111(2) years |
| 25 September 2003 Internal T.I. 2003-0032837 F - Market Maker: Reserve Account for Losses
Also released under document number 2003-00328370.
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Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | payment of deferred commission amounts held as contingency loss reserve from old employer to new employer was a payment of “remuneration” subject to withholding | |
| General Concepts - Payment & Receipt | constructive receipt by employee where reserve loss account (funded out of commissions) is transferred from old brokerage employer to new brokerage employer | ||
| 2003-10-03 | 24 September 2003 External T.I. 2003-0028145 F - DON FAIT PAR UN PARTICULIER NON-RESIDENT
Also released under document number 2003-00281450.
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Income Tax Act - Section 118.1 - Subsection 118.1(3) | non-resident can carry forward a credit five years to when Canadian residence is acquired |