We have translated 7 more CRA severed letters
8 May 2023 - 10:55pm
Email this ContentWe have a translated another CRA ruling released earlier in the year and 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 2,458 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 |
|---|---|---|---|
| 2023-02-22 | 2022 Ruling 2022-0933261R3 F - Subsection 104(4) and pipeline transaction | Income Tax Act - Section 84 - Subsection 84(2) | pipeline transaction for a trust realizing a s. 104(4)(b) gain and using a non-controlled Newco |
| 2003-06-20 | 16 June 2003 Internal T.I. 2003-0007867 F - COMPENSATION LORS DU DECES D'UN PARENT
Also released under document number 2003-00078670.
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| Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(g.1) | compensation for loss of financial support due to parental death did not qualify | ||
| 2003-06-13 | 11 June 2003 External T.I. 2002-0175975 F - TRANSFERT-ENT. EXPLOITEE ACTIVEMENT
Also released under document number 2002-01759750.
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Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(f) - Subparagraph 110.6(14)(f)(ii) | application of 24-month test where assets of business transferred to partnership of individuals, transferred to corporation under s. 95(2), partnership wound-up under s. 98(3) and shares sold |
| Income Tax Act - Section 79.1 - Subsection 79.1(6) - Paragraph 79.1(6)(b) | meaning of expenses incurred to protect creditor's rights | ||
| 13 June 2003 External T.I. 2002-0177045 F - BOISSONS OFFERTES AUX EMPLOYES
Also released under document number 2002-01770450.
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Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | FMV of free beverages marketed by employer and provided to its employees included in their income | |
| Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(d) | FMV of free beverages provided to employees included in their income, so that cost of beverages to employer deductible from its income | ||
| 27 May 2003 Internal T.I. 2003-0005357 F - TRANSFERT DE PROPRIETE EFFECTIVE
Also released under document number 2003-00053570.
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Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (e) | whether a preliminary transfer of shares of the target to spouse represented a disposition to her turned on whether there was a transfer of ownership under the Civil Code | |
| 15 May 2003 Internal T.I. 2003-0014507 F - DEDUCTIBILITE DES INTERETS
Also released under document number 2003-00145070.
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Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest deductible on money borrowed to acquire non-dividend-paying common shares | |
| 3 June 2003 Internal T.I. 2003-0181487 F - DEDUCTIBILITE DES INTERETS GARANTIE
Also released under document number 2003-01814870.
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Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | guarantee of wholly-owned corporation’s debt given for income-producing purpose is satisfied with borrowed money on which interest may be deductible | |
| Income Tax Act - Section 20.1 - Subsection 20.1(1) | s. 20.1(1)(b)(iv) deductibility where guarantee of wholly-owned corporation’s debt given for income-producing purpose is satisfied with borrowed money and subrogated claim is worthless |