We have translated 7 more CRA severed letters
23 October 2023 - 11:43pm
Email this ContentWe have translated a CRA ruling released last week and a further 6 CRA interpretations released during October of 2002. Their descriptors and links appear below.
These are additions to our set of 2,618 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 21 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 |
|---|---|---|---|
| 2023-10-18 | 2022 Ruling 2022-0937661R3 F - 104(4) and pipeline transaction | Income Tax Act - Section 84 - Subsection 84(2) | pipeline transaction to raise the funds for the application of the CRA s. 104(5.8) GAAR position to an inter vivos trust used to try to avoid the 21-year deemed disposition |
| Income Tax Act - 101-110 - Section 104 - Subsection 104(5.8) | GAAR applicable to trust holding a corporate beneficiary that was distributed property from an inter vivos trust approaching its 21st anniversary | ||
| Income Tax Act - Section 245 - Subsection 245(2) | GAAR treated as self-applying | ||
| 2002-10-25 | 5 November 2002 External T.I. 2002-0161695 F - CDC HYPOTHEQUE | Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) | no credit to CDA of creditor on receiving life insurance proceeds pursuant to pledged policy of debtor |
| 2002-10-11 | 30 October 2002 External T.I. 2002-0132745 F - RENOVATION A UN IMMEUBLE | Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense | expenditure to restore a building to its original condition may be a current expense |
| 29 October 2002 External T.I. 2002-0135815 F - BONI CADEAUX RECOMPENSES | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | bonus received by employees under a profit-sharing program not covered by gifts exclusion in ITTN No. 22 | |
| 31 October 2002 External T.I. 2002-0141265 F - NATURE D'UN BIEN APRES ROULEMENT | Income Tax Act - Section 9 - Capital Gain vs. Profit - Real Estate | property does not change its character as capital property where transferred to related corporation under s. 85(1) for immediate sale | |
| Income Tax Act - Section 69 - Subsection 69(11) | no GAAR abuse where transfer of appreciated capital property to affiliated Lossco for immediate sale | ||
| 4 November 2002 External T.I. 2002-0158885 F - Alloc. of Safe Inc. & Disc. Div. Shares | Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | payment of dividends on discretionary dividend shares with no liquidation entitlement would not result in a significant reduction | |
| 30 October 2002 External T.I. 2002-0126045 F - TRANSFERT A UN MINEUR | Income Tax Act - Section 248 - Subsection 248(1) - Specified Member | contributions of the specified member to the partnership business must be instrumental to its success |