We have translated 6 more CRA interpretations
9 October 2023 - 11:31pm
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 2,603 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 |
|---|---|---|---|
| 2002-11-08 | 15 November 2002 Internal T.I. 2002-0162427 F - Price Adjustment Clause & 85(7.1) | General Concepts - Effective Date | large FMV discrepancy suggested lack of bona fide valuation so that price adjustment clause need not be applied/ if applied, s. 85(1) election must be amended |
| Income Tax Act - Section 85 - Subsection 85(7) | amended s. 85(1) election must be filed if price-adjustment clause applied | ||
| Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(e.2) | significant FMV shortfall suggested that a benefit was desired to be conferred | ||
| 14 November 2002 Internal T.I. 2002-0169957 F - "Exercice" - Effet de 134.2 | Income Tax Act - Section 134.2 - Subsection 134.2(2) | s. 134.2 election has no effect on corporation’s fiscal period | |
| Income Tax Act - Section 249.1 - Subsection 249.1(1) | s. 134.2 election affects only the corporation's current taxation year and not its fiscal period | ||
| 6 November 2002 External T.I. 2002-0170545 F - Section 55(3)(a) - Exception55(3)(a) | Income Tax Act - Section 55 - Subsection 55(4) | s. 55(4) inapplicable where parent retained de jure control primarily for protection of their economic interest | |
| 6 November 2002 External T.I. 2002-0132395 F - Robot Class 10 Catégorie 10 | Income Tax Regulations - Schedules - Schedule II - Class 10 - Paragraph 10(a) | cost of remote-controlled duct-inspecting robot to be allocated between Class 10(a) (“automotive equipment” – which is broadly construed) and Class 8(j) (“radiocommunication equipment”) | |
| Income Tax Regulations - Schedules - Schedule II - Class 8 - Paragraph 8(j) | cost of remote-controlled duct-inspecting robot to be allocated between Class 10(a) (“automotive equipment”) and Class 8(j) (“radiocommunication equipment” – informed by IA meaning of “radiocommunication”) | ||
| 27 November 2002 Internal T.I. 2002-0149207 F - INTERETS ET FRAIS LEGAUX | Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) | prejudgment interest included in damages received for defective work on the recipients’ personal homes was taxable | |
| 5 December 2002 Internal T.I. 2002-0155187 F - DEPENSES PERSONNELLES | Income Tax Act - Section 248 - Subsection 248(16) | ITRs, like ITCs, treated as government assistance, so that included under s. 12(1)(x) unless s. 12(2.2) election made | |
| Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(hh) | repayment of ITRs would result in deduction under s. 20(1)(hh)(i) or (ii) depending on whether or not an s. 12(2.2) election had been made |