We have translated 6 more CRA interpretations
2 October 2023 - 11:02pm
Email this ContentWe have translated a further 6 CRA interpretations released during November of 2002. Their descriptors and links appear below.
These are additions to our set of 2,597 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 |
|---|---|---|---|
| 2002-11-22 | 28 November 2002 Internal T.I. 2002-0153837 F - SOMMES IMPAYEES | Income Tax Act - Section 78 - Subsection 78(1) - Paragraph 78(1)(a) | IT-109R, para. 12(a) not applied where there was an asymmetry between the deduction/ net inclusion amounts reported by the debtor and creditor |
| 5 December 2002 Internal T.I. 2002-0155667 F - DEDUCTIBILITE DES INTERETS CAPITALISEES | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | capitalized simple interest on loan to acquire common shares was deductible if reasonable expectation of dividends | |
| Income Tax Act - Section 80 - Subsection 80(2) - Paragraph 80(2)(b) | debt forgiveness rules do not apply to forgiveness of compound interest | ||
| Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount | debt forgiveness rules do not apply to forgiveness of compound interest | ||
| 5 December 2002 External T.I. 2002-0163135 F - Source Deductions - Nominal Partnership | Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | an individual could cover the payroll of the employees of him and another in agreed proportions as agent and principal, and handle all the source deductions, and prepare one information return | |
| General Concepts - Agency | paymaster under payroll agency arrangements could fulfill the source deduction and T4 reporting requirements of the principal | ||
| 5 December 2002 Internal T.I. 2002-0171847 F - RESIDENCE D'UNE FIDUCIE | Income Tax Act - Section 15 - Subsection 15(2.1) | s. 15(2) applies to loan made by a corporation to a personal trust of which its shareholder is a beneficiary | |
| Income Tax Act - Section 54 - Principal Residence - Paragraph (c.1) - Subparagraph (c.1)(ii) | principal residence designation is available in respect of a specified beneficiary even though the residence is rented by the trust to that beneficiary | ||
| 4 December 2002 Internal T.I. 2002-0138067 F - REMPLACEMENT D'UNE CREANCE PAR UNE AUTRE | Income Tax Act - Section 18 - Subsection 18(9.1) - Paragraph 18(9.1)(a) | financing the repayment of a debt obligation with the proceeds of a borrowing from a different creditor does not constitute a debt substitution | |
| 2002-11-08 | 21 November 2002 External T.I. 2002-0156565 F - INTERETS HYPOTHEQUE SUR RESIDENCE | Income Tax Act - Section 20 - Subsection 20(3) | interest on new home mortgage deductible if used to pay off mortgage on old home that had been used for income-producing purposes |