We have translated 7 more CRA interpretations
5 June 2023 - 11:01pm
Email this ContentWe have translated an interpretations 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 2,487 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 20 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 |
|---|---|---|---|
| 2023-05-31 | 8 March 2023 External T.I. 2017-0729871E5 F - Déduction supplémentaire prévue au sous-alinéa 110 | Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(c.1) | transfer of Class 14.1 property on s 85 rollover basis eliminated the additional 2% CCA under Reg. 1100(1)(c.1)(i) |
| 2003-05-23 | 13 May 2003 Internal T.I. 2003-0001787 F - CHOIX-IMPACT SUR FNACC
Also released under document number 2003-00017870.
|
Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e.1) | notwithstanding Finance’s intent, s. 104(19) election resulted in subsequent recapture |
| Statutory Interpretation - Ordinary Meaning | clearly expressed legislative text to be followed, even though contrary to more favourable Finance intent | ||
| 13 May 2003 Internal T.I. 2003-0002167 F - TRAVAIL TEMPORAIRE
Also released under document number 2003-00021670.
|
Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) - Subparagraph 6(6)(a)(i) | test of work of a temporary nature not met where appointment as a director could be readily renewed through re-election | |
| 2003-05-16 | 16 May 2003 External T.I. 2002-0178685 F - CALCUL DU COUT D'UN TITRE DE CREANCE
Also released under document number 2002-01786850.
|
Income Tax Act - Section 20 - Subsection 20(14) | overview of s. 20(14) and s. 53(2)(l) |
| Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(l) | accrued interest initially included in ACB | ||
| 13 May 2003 External T.I. 2002-0176525 F - CHANTIER DE CONSTRUCTION
Also released under document number 2002-01765250.
|
Income Tax Act - Section 6 - Subsection 6(6) | W2 amounts likely not an appropriate basis for establishing proper s. 6(6) allowance amounts | |
| 2003-05-09 | 7 May 2003 External T.I. 2002-0164995 F - SENS DE ENSEMBLE DES BENEFICIE
Also released under document number 2002-01649950.
|
Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Beneficiary | whether meaning of “beneficiary” outside ss. 104-108 includes those in the class who have not been designated depends on the context |
| Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(c) - Subparagraph 110.6(14)(c)(ii) | “all of the beneficiaries” only references those of the potential class who have been designated as beneficiaries | ||
| 7 May 2003 External T.I. 2003-0182755 F - Superficial Loss on Shares
Also released under document number 2003-01827550.
|
Income Tax Act - Section 54 - Superficial Loss | transactions for sale by individual to her husband circumvented s. 40(2)(g)(i) through the sale by him back to her RRSP, and could be GAARable | |
| Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(iv) - Clause 40(2)(g)(iv)(B) | sale by individual to her husband followed by immediate sale by him to her RRSP, circumvented s. 40(2)(g)(iv)(B) |