We have translated 7 more CRA interpretations

28 August 2023 - 11:10pm
Email this ContentEmail this Content

We have translated 7 further CRA interpretations released in February and January of 2003. Their descriptors and links appear below.

These are additions to our set of 2,565 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 ½ 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
2003-02-07 5 February 2003 External T.I. 2002-0157445 F - AAPE ACTION ADM PETITE ENTREPRISE Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (c) question of fact whether shares of stock-trading corporation were QSBCs
Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation CCRA articulation of Ensite test in relation to stock-trading business
31 January 2003 External T.I. 2002-0161555 F - VENTE D'UN IMMEUBLE LOCATIF Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) payment made by vendor to purchaser of building reduced its proceeds of disposition
3 February 2003 Internal T.I. 2002-0168317 F - PAIEMENT DE DEPENSES Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount amount recipient does not qualify as having discretion as to use if a court order specifies the expenses that are covered
Income Tax Act - Section 56.1 - Subsection 56.1(2) express mention of ss. 56.1(2) and 60.1(2) no longer required
2003-01-24 21 January 2003 External T.I. 2001-0109445 F - Usufruit-droit privé français-nu-prop. Cdn.
recap and follow-up in 2003-0002465 F

 Income Tax Act - Section 70 - Subsection 70(5) when usufruct created by will, legatee of bare ownership acquired it at FMV of bare ownership
Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) bare owner of rental property not entitled to claim CCA
10 November 2002 External T.I. 2002-0156845 F - CONGRE 2002 APFF Income Tax Act - Section 7 - Subsection 7(1.1) realization of s. 7(1.1) gain on shares’ disposition even though they had lost most of their value
13 January 2003 External T.I. 2002-0176905 F - CPCC Status Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation - Paragraph (b) test of majority-ownership of voting shares
27 January 2003 Internal T.I. 2002-0177197 F - ATTRIBUTION DU GAIN A UN CONJOINT SEPARE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount net rental income on property received by separated spouse to fund support was rental income, not a support amount
Income Tax Act - Section 74.5 - Subsection 74.5(3) - Paragraph 74.5(3)(b) application of s. 74.5(3)(b) re properties divided between the separated spouses and sold before divorce