We have translated 7 more CRA interpretations
18 September 2023 - 11:29pm
Email this ContentWe have translated a CRA interpretation released last week and a further 6 CRA interpretations released during December of 2002. Their descriptors and links appear below.
These are additions to our set of 2,584 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 |
|---|---|---|---|
| 2023-09-13 | 11 September 2017 External T.I. 2017-0706851E5 F - Changement partiel d'usage - Immeuble locatif | Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) - Subparagraph 45(1)(c)(i) | partial change-of-use rules applied when a non-resident with a s. 216 rental triplex immigrates to Canada and moves into one of the units |
| Income Tax Act - Section 216 - Subsection 216(1) | previous s. 216 use of property taken into account, following immigration to Canada, under ss. 13(7)(d)(ii) and 45(1)(c)(i) | ||
| 2002-12-20 | 23 December 2002 Internal T.I. 2002-0176087 F - LIMITE APPLICABLE TRANSFER DANS REER | Income Tax Act - Section 146.3 - Subsection 146.3(6.1) | deemed benefit under s. 146.3(6.1) included in amount referred to in s. 146.3(5) |
| Income Tax Act - Section 146.3 - Subsection 146.3(6.11) - Paragraph 146.3(6.11)(b) - Variable C | Variable C included the deemed benefit under s. 146.3(6.1) | ||
| 12 December 2002 External T.I. 2002-0146175 F - Losses Incurred by a Taxpayer ect...... | Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) - Subparagraph 39(1)(c)(iii) | usual s. 50(1)(b)(i) and SBC qualification rules applied to shares of a cooperative corporation that became bankrupt | |
| 11 December 2002 Internal T.I. 2002-0173007 F - Observation aux commentaires (OCDE) | Treaties - Income Tax Conventions - Article 12 | Canada’s withdrawal of its observation on Art. 12 on March 28, 2002 was prospective, and did not affect its right to impose withholding tax on payments for use of a secret process prior to that date | |
| 2002-12-06 | 16 December 2002 External T.I. 2002-0138195 F - ALLOCATION POUR FRAIS DE DEPLACEMENT | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii.1) | travel allowance for travel 40% of the employment days between home and a more remote employer situs was for personal travel |
| Income Tax Act - Section 81 - Subsection 81(3.1) | amalgamation of 2 part-time employers ended the s. 81(3.1) exclusion so that travel allowance was for personal travel | ||
| 17 December 2002 External T.I. 2002-0158165 F - REPAS DE FETE OFFERTS PAR L'EMPLOYEUR | Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(f) | monthly restaurant event for only those employees whose birthday month it was would not qualify/ restaurant implicitly the employer’s place of business | |
| 20 December 2002 External T.I. 2002-0159365 F - REMUNERATION NON MONETAIRE | Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | no source deduction or remittance obligations where all remuneration is non-monetary |