We have translated 7 more CRA interpretations

25 September 2023 - 11:46pm
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We have translated a CRA interpretation released last week and a further 6 CRA interpretations released during December and November of 2002. Their descriptors and links appear below.

These are additions to our set of 2,591 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
2023-09-20 5 July 2023 External T.I. 2022-0954271E5 F - Retention of books and records Income Tax Regulations - Regulation 5800 - Subsection 5800(1) - Paragraph 5800(1)(a) - Subparagraph 5800(1)(a)(iv) generally only the GL rather than ancillary journals or back-up are subject to the extended corporate accounting-record retention period
Income Tax Regulations - Regulation 5800 - Subsection 5800(1) - Paragraph 5800(1)(a) - Subparagraph 5800(1)(a)(v) special contract is one containing an unusual provision
2002-12-06 18 December 2002 Internal T.I. 2002-0164817 F - HONORAIRES POUR SERVICES DE MANDATAIRE Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose fees paid to a management company whose employees were employed by the professional recipient may not be incurred for an income-producing purpose
Income Tax Act - Section 67 CCRA policy on cost-plus-15% management companies of a professional inapplicable where it is providing agency services
2002-11-22 6 December 2002 External T.I. 2002-0152085 F - PERSONNE A CHARGE TRANSFER D'UN MONTANT Income Tax Act - Section 118.3 - Subsection 118.3(3) credit transferee need not be the sole provider
5 December 2002 External T.I. 2002-0172315 F - Contingent Right to Acquire Shares Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) ss. 251(5)(b) and 256(1.4) applicable where the 3 equal shareholders agree that they must purchase the shares of anyone committing fraud – but not if redemption requirement
2002-11-08 25 November 2002 External T.I. 2002-0126825 F - AVANTAGE CONFERE A UN EMPLOYE Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) reimbursing employee-tenants for time spent in upgrading their units beyond normal rental industry practice would generate a taxable benefit
4 December 2002 External T.I. 2002-0139345 F - REVENUS D'INTERETS Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) income of dependant child includes interest income generated from tax-free receipts
2 December 2002 External T.I. 2002-0151325 F - FRAIS DEPLACEMENT Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) tacit requirement could not be invoked where the collective agreement explicitly assigned responsibility for travel expenses to the employer (who refused to pay)