We have translated 7 more CRA severed letters
22 May 2023 - 11:08pm
We have a translated an interpretation released by CRA last week and a further 6 translations of CRA interpretations released in May of 2003. Their descriptors and links appear below.
These are additions to our set of 2,471 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|
|2023-05-17||15 February 2023 External T.I. 2022-0953991E5 F - Paragraph 84.1(2)(e) and amalgamation||Income Tax Act - Section 84.1 - Subsection 84.1(2) - Paragraph 84.1(2)(e)||loss of s. 84.1(2)(e) safe harbour on an amalgamation of the purchaser and subject corporation|
|2003-05-30||5 May 2003 External T.I. 2002-0140805 F - Arrangements funéraire - Provision de 20(1)m)
Also released under document number 2002-01408050.
|Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m)||non-refundable prepaid funeral amounts not held in trust were not eligible for the reserve|
|23 April 2003 External T.I. 2002-0155125 F - Rétribution Questionnaires - Actionnaires
Also released under document number 2002-01551250.
|Income Tax Act - Section 67||scenario including non-resident corporation did not comply with ITTN No. 22|
|23 May 2003 External T.I. 2002-0172205 F - FIDUCIE DE BIEN-RE&S
Also released under document number 2002-01722050.
|Income Tax Act - Section 18 - Subsection 18(9) - Paragraph 18(9)(a) - Subparagraph 18(9)(a)(iii)||s. 18(9)(a)(iii) likely applies where employer makes a payment to a trust which uses insurance to fund employee health services|
|26 May 2003 External T.I. 2002-0180455 F - MODIFICATION D'UNE POLICE EXONEREE
Also released under document number 2002-01804550.
|Income Tax Regulations - Regulation 306 - Subsection 306(1)||question of fact for insurer whether splitting a policy terminates its exempt status|
|26 May 2003 Internal T.I. 2003-0002297 F - Fonds commun de placement-Dépenses gén.
Also released under document number 2003-00022970.
|Income Tax Act - 101-110 - Section 104 - Subsection 104(6)||allocation of expenses permitted to maximize dividend tax credits of MFT beneficiaries|
|Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb)||s. 20(1)(bb) deductibility does not turn on the evaluated security being acquired|
|15 April 2003 External T.I. 2002-0139305 F - Immigration
Also released under document number 2002-01393050.
|Income Tax Act - Section 128.1 - Subsection 128.1(1) - Paragraph 128.1(1)(c)||ss. 128.1(1)(b) and (c), unlike former s. 48(3), apply also for CCA/recapture purposes|
|Income Tax Act - Section 126 - Subsection 126(1)||FTC can be generated where recapture of depreciation, and denied capital loss, are realized on a US rental building|
|Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i)||step-up of partnership interest on immigration to Canada neutralized the capital gain on partnership property when partnership wound up|