We have translated 7 more CRA interpretations
27 March 2023 - 11:35pm
Email this ContentWe have published a translation of a CRA interpretation released last week and 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 2,417 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 |
|---|---|---|---|
| 2023-03-22 | 23 December 2022 Internal T.I. 2021-0880421I7 F - SUCL - Dépenses de loyer admissibles | Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Rent Expense - Variable A - Paragraph (b) - Subparagraph (b)(i) | government assistance does not reduce interest |
| 2003-09-12 | 26 June 2003 Internal T.I. 2002-0169607 F - Sécurité sociale française
Also released under document number 2002-01696070.
|
Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | French payroll taxes and social security contributions qualified as non-business income taxes |
| 1 August 2003 Internal T.I. 2003-0009697 F - Usufruit et amortissement
Also released under document number 2003-00096970.
|
Income Tax Act - Section 248 - Subsection 248(3) | s. 248(3) generates CCA claim to deemed trust, whereas previously no CCA was available | |
| Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | bare owner not entitled to claim CCA on property even if s. 248(3) does not apply | ||
| 22 July 2003 Internal T.I. 2003-0018027 F - Fondation du Liechtenstein
Also released under document number 2003-00180270.
|
Income Tax Act - Section 248 - Subsection 248(1) - Corporation | Liechtenstein sifting was a corporation rather than trust | |
| Income Tax Act - Section 95 - Subsection 95(1) - Controlled Foreign Affiliate | Liechtenstein sifting in which the resident individual had a life interest was to be treated as a 100% CFA | ||
| Income Tax Act - Section 94 - Subsection 94(3) | Liechtenstein siftung was corporation, not trust | ||
| 28 August 2003 Internal T.I. 2003-0019767 F - Investissement dans une société étrangère
Also released under document number 2003-00197670.
|
Income Tax Act - Section 95 - Subsection 95(1) - Controlled Foreign Affiliate | redeemable convertible rights of a Canco investor in Foreignco were not shares, so that Foreignco was not a CFA | |
| Income Tax Act - Section 17 - Subsection 17(1) | redeemable convertible rights of a Canco investor in Foreignco had not been redeemed, so that they were not debt for s. 17 purposes and Foreignco was not a CFA | ||
| Income Tax Act - Section 94.1 - Subsection 94.1(1) | inferred satisfaction of main reason test where all stock market investment income and gains were reinvested free of local tax | ||
| 27 August 2003 Internal T.I. 2003-0019857 F - Attribution de dividendes par un RPEB
Also released under document number 2003-00198570.
|
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(d) | dividends allocated to a non-resident beneficiary by an EPSP were taxable to the extent that the allocation related to duties performed in Canada | |
| Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) | dividends allocated to a non-resident beneficiary by an EPSP in respect of duties performed in Canada were taxable under ss. 6(1)(d) and 115(1)(a)(i) | ||
| 2003-09-05 | 5 August 2003 External T.I. 2003-0027705 F - DON A UN ENFANT MAJEUR
Also released under document number 2003-00277050.
|
Income Tax Act - Section 74.1 - Subsection 74.1(2) | no attribution on income from gift to child over 17 |