We have translated 7 more CRA interpretations

8 August 2023 - 12:13am
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We have translated a CRA interpretation released on July 12, 2023 and 6 translations of CRA interpretations released in March of 2003. Their descriptors and links appear below.

These are additions to our set of 2,546 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
2023-07-12 12 June 2023 External T.I. 2018-0750361E5 F - Transfert d’un terrain Income Tax Act - Section 152 - Subsection 152(1) CRA mandate is to interpret the ITA and not provide tax-planning advice
2003-03-14 14 February 2003 External T.I. 2002-0173195 F - Transfer of Shares Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) s. 6(1)(a) generally applicable to gift of shares by majority owner to key employee, but not to employee son
Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) s. 69(1)(b) rather than s. 6(1)(a) generally applicable to gift of majority ownership of CCPC to employee son
11 March 2003 Internal T.I. 2002-0180997 F - CONGE A TRAITEMENT DIFFERE Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(1)(a)(v) timing of taxation from breaking Reg. 6801(a)(vi) depends on timing of break decision/ full-timer must return to full-time work
Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(a)(iv) employee can reduce the leave in order to reduce the resumed-work requirement
13 March 2003 Internal T.I. 2003-0183697 F - FRAIS DE GARDE Income Tax Act - Section 63 - Subsection 63(3) - Child Care Expense child care expenses can include liquidated damages for early termination of daycare contract
2003-03-07 4 March 2003 External T.I. 2002-0150985 F - TRANSFERT-RESIDENCE PRINCIPALE Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) s. 40(2)(b) deduction available on transfer of residence to wholly-owned corporation
28 February 2003 External T.I. 2002-0163425 F - LEGS PARTICULIER AVEC CHARGE ET REER Income Tax Act - Section 146 - Subsection 146(1) - Refund of Premiums particular legacy paid out of RRSP of deceased annuitant can qualify as refund of premiums even if it is charged with another legacy
6 March 2003 External T.I. 2002-0166855 F - CADEAU EN QUASI-SPECES Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) cash equivalent exclusion from accommodation of employee gifts and awards