We have translated 7 more CRA interpretations

3 April 2023 - 11:36pm
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We have published a translation of a CRA interpretation released last week and a further 6 translations of CRA interpretations released in September and August of 2003. Their descriptors and links appear below.

These are additions to our set of 2,424 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 2/3 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
2023-03-29 23 January 2023 External T.I. 2020-0865161E5 F - SSUC/CEWS – Sous-alinéa 125.7(4)e)(i) et personne Income Tax Act - Section 125.7 - Subsection 125.7(4) - Paragraph 125.7(4)(e) electing taxpayer can receive amounts through third party where receipt on its behalf is established by agreement or statute
General Concepts - Payment & Receipt a cash-basis taxpayer can receive an amount when it is received through a third party
2003-09-05 15 April 2003 Internal T.I. 2002-0176687 F - IMPOT DES GRANDES SOCIETES AVANCES
Also released under document number 2002-01766870.

 Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(c) prepaid revenues deducted under s. 20(6) were not a reserve
Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(b) prepaid revenues were an “advance”
17 June 2003 Internal T.I. 2003-0020677 F - PARTIE I.E IMPOTS DES GRANDES SOCIETES
Also released under document number 2003-00206770.

 Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(c) prepaid services were includible as advances
2003-08-01 28 July 2003 External T.I. 2003-0026395 F - PLACEMENT ADMISSIBLE REEE
Also released under document number 2003-00263950.

 Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (e) disposition on transfer of shares to registered plan
22 July 2003 External T.I. 2002-0175715 F - GAIN EN CAPITAL RESIDENCE PRINCIPALE
Also released under document number 2002-01757150.

 Income Tax Act - Section 54 - Principal Residence - Paragraph (e) Quebec agricultural lands controls would not have precluded the taxpayer from acquiring only ½ hectare for principal residence use
29 July 2003 External T.I. 2003-0009115 F - FRAIS DE DEMENAGEMENT
Also released under document number 2003-00091150.

 Income Tax Act - Section 248 - Subsection 248(1) - Eligible Relocation moving to a new employer in the same building (with longer hours) potentially could be grounds for an eligible relocation
29 July 2003 External T.I. 2003-0012335 F - PLACEMENT A RENDEMENT PROGRESSIF
Also released under document number 2003-00123350.

 Income Tax Regulations - Regulation 7000 - Subsection 7000(1) - Paragraph 7000(1)(c) accommodation of contingently slightly-increasing interest rate no longer applicable