We have translated 6 more CRA interpretations
10 July 2023 - 11:42pm
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 2,521 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 ¼ 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 |
|---|---|---|---|
| 2003-04-04 | 17 March 2003 External T.I. 2002-0130685 F - Limite inférieure - JVM Participation
Also released under document number 2002-01306850.
|
Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Trust - Paragraph (g) | meaning of vested indefeasibly |
| Income Tax Act - 101-110 - Section 107.4 - Subsection 107.4(4) | purpose of s. 107.4(4) | ||
| 4 April 2003 Internal T.I. 2003-0004387 F - OUTIL ADMISSIBLE APPRENTI MECANICIEN
Also released under document number 2003-00043870.
|
Income Tax Act - Section 8 - Subsection 8(6) - Paragraph 8(6)(b) - Subparagraph 8(6)(b)(ii) | tool that is resold without being used qualifies as “new” to the purchaser | |
| 12 March 2003 External T.I. 2002-0176955 F - Retenu dividende français
Also released under document number 2002-01769550.
|
Treaties - Income Tax Conventions - Article 10 | Canadian mutual fund trust or pension fund trust deemed to be the beneficial owner of dividends by Art. 29(7)(a) of the Canada-France Convention | |
| 31 March 2003 External T.I. 2003-0006305 F - Safe Income Discretionary Dividend
Commented on in 2010-0388821E5 F; also released under document number 2003-00063050.
|
Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | questionable to allocate all SIOH to the class of discretionary dividend shares on which a dividend is paid/ cannot attribute pre-issuance safe income to a share | |
| 27 March 2003 External T.I. 2002-0178035 F - HYPOTHEQUE PLACEMENT ADMISSIBLE
Also released under document number 2002-01780350.
|
Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(j) | no requirement that the mortgage be a first mortgage or a residential mortgage | |
| 27 March 2003 External T.I. 2002-0180045 F - DEDUCTION DES INTERETS
Also released under document number 2002-01800450.
|
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | s. 245(1) might be applied to transactions to convert non-deductible mortgage interest to deductible interest pursuant to sale of shares to borrowing wife and use of s. 74.1(1) | |
| Income Tax Act - Section 74.1 - Subsection 74.1(1) | s. 74.1(1) attributes income or loss after deduction of interest expense |