We have translated 6 more CRA interpretations
1 May 2023 - 11:41pm
Email this ContentWe have a further 6 translations of CRA interpretations released in June of 2003. Their descriptors and links appear below.
These are additions to our set of 2,451 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 ¾ 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 |
|---|---|---|---|
| 2003-06-27 | 19 June 2003 Internal T.I. 2003-0021297 F - LOI SUR L'ACCISE PENALITES INTERETS
Also released under document number 2003-00212970.
|
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | GST/HST interest deductible if incurred re deductible expenditure/ penalties may also be deductible |
| Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(t) | GST/HST interest and penalties are deductible based on application of ordinary principles | ||
| 2003-06-20 | 13 June 2003 External T.I. 2003-0184285 F - ALLOCATION DE RETRAITE
Also released under document number 2003-01842850.
|
Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | if no guarantee or offer of new employment, the individual has retired |
| 10 June 2003 External T.I. 2003-0017065 F - Disp. of Property owned on Dec 31, 71
Also released under document number 2003-00170650.
|
Income Tax Act - Section 85 - Subsection 85(5) | the capital cost is not reduced by s. 85(5) for non-CCA/recapture purposes | |
| Income Tax Application Rules - Subsection 20(1) | 2 detailed examples of the application of ITAR 20(1) | ||
| 10 June 2003 External T.I. 2003-0018915 F - Attribution - Transfers & Loans to Corp.
Also released under document number 2003-00189150.
|
Income Tax Act - Section 74.5 - Subsection 74.5(6) | s. 74.5(6) applied to an estate-freeze exchange by individual’s Holdco of Opco common shares for preferred shares so that family trust could subscribe for Opco common shares | |
| 12 June 2003 External T.I. 2003-0019725 F - Sale of Holding' Shares to OPCO
Also released under document number 2003-00197250.
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Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | 3 unrelated individuals likely acting in concert where they act without separate interests to achieve a basis step-up re transactions that are irrelevant to the business of the other party (Opco) | |
| Income Tax Act - Section 84.1 - Subsection 84.1(1) | s. 84.1 likely applicable re transaction in which 3 unrelated individuals act in concert to step up shares in Opco | ||
| 16 June 2003 External T.I. 2003-0020895 F - Association/Convertible Property
Also released under document number 2003-00208950.
|
Income Tax Act - Section 256 - Subsection 256(1.4) - Paragraph 256(1.4)(a) | where multiple debenture holders hold convertible debentures, s. 256(1.4)(a) is to be applied as if all the debentures were exercised (so that each debenture holder is diluted by the others) | |
| Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) | where multiple debenture holders hold convertible debentures, s. 256(1.4)(a) is to be applied as if all the debentures were exercised simultaneously |