We have translated 7 more CRA interpretations

We 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