We have translated 6 more CRA interpretations
26 June 2023 - 11:07pm
Email this ContentWe have translated a further 6 translations of CRA interpretations released in April of 2003. Their descriptors and links appear below.
These are additions to our set of 2,508 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 |
|---|---|---|---|
| 2003-04-18 | 10 April 2003 Internal T.I. 2002-0177767 F - INDEMNITE RECUE PAR UN ARTISTE
Also released under document number 2002-01777670.
|
Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (f) | damages for infringement of an artist’s moral rights could be proceeds of disposition of a capital property |
| Income Tax Act - Section 248 - Subsection 248(1) - Property | the moral rights of an artist were property | ||
| 17 April 2003 Internal T.I. 2003-0006407 F - PRET SANS INTERET DEDUCTIBILITY INTERETS
Also released under document number 2003-00064070.
|
Income Tax Act - Section 20.1 - Subsection 20.1(1) | s. 20.1(1)(b)(iv) can apply to money borrowed for an interest-free loan that was a source under the exceptional circumstances test | |
| 2003-04-11 | 9 April 2003 External T.I. 2003-0008735 F - DONATION XXXXXXXXXX
Also released under document number 2003-00087350.
|
Income Tax Act - Section 248 - Subsection 248(31) | guidelines in ITTN No. 26 followed |
| 4 April 2003 External T.I. 2002-0171635 F - PERTE APPARENTE
Also released under document number 2002-01716350.
|
Income Tax Act - Section 54 - Superficial Loss | purchase within 30 days by daughter of share vendor did not engage the superficial loss rules | |
| Income Tax Act - Section 40 - Subsection 40(3.3) | purchase within 30 days by daughter of share vendor’s controlling shareholder did not engage the superficial loss rules | ||
| Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(a) | father and daughter not affiliated | ||
| Income Tax Act - Section 251.1 - Subsection 251.1(1) - Paragraph 251.1(1)(b) | corporation and daughter of its controlling shareholder not affiliated | ||
| 4 April 2003 External T.I. 2002-0176305 F - DON PAR TESTAMENT
Also released under document number 2002-01763050.
|
Income Tax Act - Section 118.1 - Subsection 118.1(5) | gift can be made by will to a foundation formed after testator’s death | |
| 3 April 2003 External T.I. 2003-0006945 F - XXXXXXXXXX
Also released under document number 2003-00069450.
|
Other Legislation/Constitution - Federal - Indian Act - Section 87 | Guideline 2 satisfied notwithstanding that Indian with reserve home needs to stay off the reserve for temporary work assignment |