We have translated over 2500 CRA severed letters
19 June 2023 - 11:58pm
Email this ContentWe have translated two interpretations released by CRA last week and a further 6 translations of CRA interpretations released in May and April of 2003. Their descriptors and links appear below.
These are additions to our set of 2,502 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 |
|---|---|---|---|
| 2023-06-14 | 23 May 2023 External T.I. 2017-0713011E5 F - Avantages imposables relatifs aux automobiles ou autres véhicules | Income Tax Act - Section 248 - Subsection 248(1) - Automobile - Paragraph (e) - Subparagraph (e)(i) | a minivan with a permanent reduction to a below-four seat capacity could be excluded from being an “automobile” |
| Income Tax Act - Section 6 - Subsection 6(2) - Element A - Paragraph A(a) | driving to or from home as a result of responding to emergency calls is not personal use | ||
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) | travel of on-call employees between home and customer sites was not personal | ||
| 13 April 2023 External T.I. 2017-0684341E5 F - Perte au titre d’un placement d’entreprise | Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) | active business for SBC purposes can continue after regular business operations have ceased/ sale of debt for $1 to unrelated purchasers might be a non-arm’s length transaction | |
| Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation | a corporation may continue to qualify as an SBC well after it has in fact ceased to transact its business | ||
| Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | sale of debt for $1 in order to trigger a loss might be a NAL transaction | ||
| Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | business does not cease until the prior commitments incurred in the course of the business are fulfilled | ||
| 2003-05-02 | 17 April 2003 Internal T.I. 2003-0181507 F - PRET SANS INTERET
Also released under document number 2003-01815070.
|
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | accessing the exceptional circumstances test requires demonstrating “a sufficient connection between the interest-free loan and an indirect source of the person's income” |
| 25 April 2003 Internal T.I. 2003-0181797 F - FRAIS JURIDIQUES-DECISION
Also released under document number 2003-01817970.
|
Income Tax Act - Section 60 - Paragraph 60(o.1) | legal expenses incurred to recover loss to taxpayer’s RRSP from negligence of investment advisor, were non-deductible | |
| 2003-04-25 | 22 April 2003 External T.I. 2002-0169565 F - ACTIF UTILISE DANS L'ENTREPRISE
Also released under document number 2002-01695650.
|
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (c) | tax credits generated from an active business due to SR&ED expenditures or over-installing are assets used in that active business as per Ensite |
| 2003-04-18 | 10 April 2003 External T.I. 2002-0152065 F - DEFINITION D'AGRICULTURE
Also released under document number 2002-01520650.
|
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property | goodwill of veterinary practice of servicing farmers did not constitute “qualified farm property” |
| Income Tax Act - Section 248 - Subsection 248(1) - Farming | veterinary practice of providing medicine to livestock was not “farming” | ||
| 11 April 2003 External T.I. 2002-0173065 F - REPAS FOURNIS COURS SEMINAIRES
Also released under document number 2002-01730650.
|
Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(a) | s. 67.1(2)(a) exception applied to meals and snacks added to the cost of training courses provided in the ordinary course | |
| 9 April 2003 External T.I. 2003-0011555 F - Application of 13(21.2) - Affil. Persons
Also released under document number 2003-00115550.
|
Income Tax Act - Section 13 - Subsection 13(21.2) | likely terminal loss where corp. equally owned by A and B disposed of beneficial co-ownership interest to corp. in which their respective spouses held 25% by each of Mrs. A and Mrs. B | |
| General Concepts - Agency | CCRA tests for accepting the presence of an agency agreement, here, re property of a nominee |