We have translated 6 more CRA interpretations
17 July 2023 - 11:55pm
Email this ContentWe have translated a further 6 translations of CRA interpretations released in April and March of 2003. Their descriptors and links appear below.
These are additions to our set of 2,527 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 1/3 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 | 24 February 2003 Internal T.I. 2002-0165537 F - Le détachement d'employés et l'article XV
Also released under document number 2002-01655370.
|
Treaties - Income Tax Conventions - Article 15 | exemption in Art. 15 of US Treaty unavailable where Canadian employee seconded to US affiliate, which reimburses for his payroll |
| 24 March 2003 Internal T.I. 2002-0177587 F - XXXXXXXXXX EN CONSIGNATION PERTE
Also released under document number 2002-01775870.
|
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs | business commences when a significant activity is initiated that is part of an income-generating process | |
| Income Tax Act - Section 9 - Timing | loss when inventory disappears is deducted when the loss is discovered | ||
| 11 March 2003 Internal T.I. 2003-0000087 F - Projet agricole au sens de 122.3(1)b)(i)(B)
Also released under document number 2003-00000870.
|
Income Tax Act - Section 248 - Subsection 248(1) - Farming | woodlot management can be farming | |
| 18 February 2003 Internal T.I. 2003-0182997 F - Calcul du revenu net étranger à 126(1)b)(i)
Also released under document number 2003-01829970.
|
Income Tax Act - Section 126 - Subsection 126(9) - Paragraph 126(9)(a) | qualifying income not reduced by s. 110(1)(d) deduction | |
| 2003-03-28 | 26 March 2003 External T.I. 2003-0008645 F - Non-Arm's Length Sale of Shares | Income Tax Act - Section 84.1 - Subsection 84.1(1) | no presumption that a transaction between companies owned by couple and nephew, respectively, is not arm’s length |
| Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) | family relationship (e.g., uncle/nephew) are more likely to give rise to NAL transaction | ||
| 24 March 2003 External T.I. 2002-0165265 F - REMBOURSEMENT DE PRIMES | Income Tax Act - Section 146 - Subsection 146(8.1) | election cannot be made with surviving spouse if bequest of RRSP is to surviving adult child |