We have translated 6 more CRA interpretations
12 September 2023 - 12:38am
Email this ContentWe have translated a CRA interpretation released last week and a further 5 CRA interpretations released during the period commencing in December of 2002. Their descriptors and links appear below.
These are additions to our set of 2,577 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 ¾ 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 |
|---|---|---|---|
| 2023-09-06 | 10 February 2022 External T.I. 2019-0819651E5 F - Pension from China | Treaties - Income Tax Conventions - Article 19 | pension from China paid to former civil servant now resident in Canada was not exempted under Art. 18 of the Canada-China Treaty |
| 2003-10-03 | 30 September 2003 External T.I. 2003-0035725 F - MONTANT RELATIF AUX ETUDES
Also released under document number 2003-00357250.
|
Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Student - Paragraph (d) | meaning of post-secondary |
| Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Student - Paragraph (a) | portion of month can be counted provided that 12 hours (including course practical work) expended in that portion | ||
| 2003-09-12 | 28 August 2009 Internal T.I. 2003-0029367 F - Paragraph 122.3
Also released under document number 2003-00293670.
|
Income Tax Act - Section 122.3 - Subsection 122.3(1) - Paragraph 122.3(1)(b) - Subparagraph 122.3(1)(b)(i) | contract can be concluded with a person related to the specified employer |
| 2002-12-20 | 7 January 2003 Internal T.I. 2002-0168347 F - RETRAITE OU PENSION ALIMENTAIRE | Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount | splitting of pension income for support purposes was alimony |
| Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) | equal share of pension income going to ex-spouse without declared element of support was received as pension income | ||
| 12 December 2002 External T.I. 2001-0100755 F - Impact of LCB on Dr and Part IV | Income Tax Act - Section 129 - Subsection 129(2) | general practice to net dividend refund against unpaid Part I tax | |
| Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b) | connected dividend recipient is not required to pay s. 186(1)(b) tax if it can demonstrate by the return-filing deadline that such tax was eliminated through a loss carryback | ||
| Income Tax Act - Section 164 - Subsection 164(1) | where subsequent loss carryback eliminates the Part I tax and dividend refund (DR), the refund interest is calculated on the initial Part I tax amount even if the DR reversal is paid by set-off | ||
| Income Tax Act - Section 160.1 - Subsection 160.1(1) | interest payable under s. 160.1(1) on the reversed dividend refund where subsequent year’s loss is carried back to eliminate the Part I tax and RDTOH | ||
| 20 December 2002 External T.I. 2002-0164735 F - PRODUIT DE DISPOSITION ACHALANDAGE | Income Tax Act - Section 14 - Subsection 14(5) - Cumulative Eligible Capital - Variable E | full potentially receivable amount must be recognized, notwithstanding subsequent possible downward adjustment | |
| Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) | s. 12(1)(g) applicable to incremental pharmacy sales price for goodwill based on volume of prescriptions for post-sale years |