We have translated 6 more CRA interpretations
15 May 2023 - 11:39pm
Email this ContentWe have a translated a further 6 translations of CRA interpretations released in June and May of 2003. Their descriptors and links appear below.
These are additions to our set of 2,464 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 |
|---|---|---|---|
| 2003-06-06 | 3 June 2003 External T.I. 2003-0012075 F - Safe Income and 104(13.1) Designation
Also released under document number 2003-00120750.
|
Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | income retained by a trust under s. 104(13.1) and then distributed to its corporate beneficiary was not included in the latter’s safe income |
| Income Tax Act - Section 55 - Subsection 55(2) | |||
| 30 May 2003 Internal T.I. 2003-0000117 F - ALLOCATION AUTOMOBLE VERSÉE
Also released under document number 2003-00001170.
|
Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(c) - Subparagraph 53(2)(c)(v) | allowance, or reimbursement for non-partnership expense, is treated as a distribution reducing the partner’s ACB | |
| Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(a) | fees, and usually "loan" interest, paid to a partner will be treated as draws rather than deductible expenses | ||
| Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | a loan by a partner to the partnership may be treated as a loan rather than a contribution of capital in special circumstances | ||
| 3 June 2003 Internal T.I. 2003-0019087 F - Calculation of 163(1) Penalty - Capital Gain
Also released under document number 2003-00190870.
|
Income Tax Act - Section 163 - Subsection 163(1) | penalty computed on taxable capital gain, not capital gain | |
| 30 May 2003 External T.I. 2003-0182145 F - AVANTAGE IMPOSABLE-VOYAGE
Also released under document number 2003-01821450.
|
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | no taxable benefit re free trip for a customer’s employee where employee spends at least 50% of the time on business-related activities | |
| 30 May 2003 External T.I. 2003-0006005 F - EQUIVALENT TO SPOUSE
Also released under document number 2003-00060050.
|
Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) - Subparagarph 118(1)(b)(i) | s. 118(1)(b)(i) test unlikely to be satisfied where one of couple is incarcerated | |
| 2003-05-30 | 27 May 2003 External T.I. 2002-0176485 F - regime d'assurance-salaire
Also released under document number 2002-01764850.
|
Income Tax Act - Section 15 - Subsection 15(1) | s. 15(1) benefit (e.g., from corporation paying premiums under wage loss replacement plan for shareholder) cannot be reduced by the shareholder repaying the benefit |