We have translated 6 more CRA interpretations
20 March 2023 - 11:40pm
Email this ContentWe have published a further 6 translations of CRA interpretations released in September of 2003. Their descriptors and links appear below.
These are additions to our set of 2,410 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 ½ 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 |
|---|---|---|---|
| 2003-09-19 | 15 September 2003 Internal T.I. 2003-0013357 F - ALLOCATION RECUE PAR UN BENEVOLE
Also released under document number 2003-00133570.
|
Income Tax Act - Section 5 - Subsection 5(1) | volunteer driver was not an employee |
| Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | volunteer driver with high activity level likely was engaged in a business | ||
| 16 September 2003 Internal T.I. 2003-0023957 F - Droits et biens crédit personne mariée
Also released under document number 2003-00239570.
|
Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(a) | income of deceased from rights or things (included in separate return) is excluded from income for s. 118(1)(a) purposes | |
| Income Tax Act - Section 70 - Subsection 70(2) | deemed separate nature of person for rights and things return | ||
| 15 September 2003 External T.I. 2003-0028075 F - Definition of "Specified Class" Sub 256(1.1)
Also released under document number 2003-00280750.
|
Income Tax Act - Section 256 - Subsection 256(1.1) - Paragraph 256(1.1)(b) | taking away of voting rights by shareholders agreement did not satisfy s. 256(1.1)(b) | |
| 2003-09-12 | 18 July 2003 External T.I. 2002-0162985 F - Renonciation et bénéficiaire
Also released under document number 2002-01629850.
|
Income Tax Act - Section 75 - Subsection 75(2) | renunciation by transferor of capital interest (but not of income interest) may avoid s. 75(2)(a)(i) if not done in advance of transfer |
| Income Tax Act - 101-110 - Section 107 - Subsection 107(4.1) - Paragraph 107(4.1)(b) | s. 107(4.1)(b) exclusion applicable if s. 75(2) was applicable at any time | ||
| 2 July 2003 External T.I. 2002-0180015 F - Usufruit d'un immeuble
Also released under document number 2002-01800150.
|
Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) - Subparagraph 69(1)(b)(i) | application of s. 69(1)(b)(i) on transfer of individual’s property to a corporation with him having the usufruct | |
| Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | transferor to a deemed s. 248(3) trust who receives a usufruct does not deal at arm’s length with the trust | ||
| Income Tax Act - 101-110 - Section 105 - Subsection 105(1) | no benefit re use of personal-use property | ||
| 29 August 2003 Internal T.I. 2003-0018497 F - L'Année d'imposition diffère
Also released under document number 2003-00184970.
|
Income Tax Act - Section 126 - Subsection 126(1) | foreign tax paid for different foreign taxation year should be prorated based on the proportions of income earned in the Canadian taxation years |