We have translated 6 more CRA interpretations
We have translated 6 further CRA interpretations released during September of 2002. Their descriptors and links appear below.
These are additions to our set of 2,636 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|
|2002-09-13||4 October 2002 Internal T.I. 2002-0139807 F - REMBOURSEMENT DE TPS||Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - J||GST rebate received after sale of asset would not, under J of UCC formula, produce recapture|
|Income Tax Act - Section 13 - Subsection 13(7.1)||GST rebate claim reduced UCC pursuant to J of formula rather than under s. 13(7.1, since claimed after asset’s disposition|
|Income Tax Act - Section 6 - Subsection 6(8) - Paragraph 6(8)(b)||GST rebate claimed by employee re CCA on car after its sale reduces UCC pursuant to J of formula rather than under s. 13(7.1)|
|4 October 2002 Internal T.I. 2001-010564A F - PENSION ALIMENTAIRE-ARRERAGES||Income Tax Act - Section 60 - Paragraph 60(b)||lump sum payment in settlement of periodic support payments in arrears is an amount payable on a periodic basis|
|General Concepts - Payment & Receipt||set-off does not constitute payment unless the parties so agree|
|2 October 2002 External T.I. 2002-0118815 F - DIABETE JUVENILE||Income Tax Act - Section 118.3 - Subsection 118.3(1) - Paragraph 118.3(1)(a.1)||child with juvenile diabetes does not generate the infirm credit, including under para. (a.1)|
|3 October 2002 External T.I. 2002-0122345 F - EN RAPPORT AVEC ENTREPRISE||Income Tax Act - Section 37 - Subsection 37(1) - Paragraph 37(1)(a) - Subparagraph 37(1)(a)(i)||related-business requirement will generally be satisfied where the results of the SR&ED, if successful, have a direct and beneficial application in the taxpayer’s business|
|Income Tax Act - Section 37 - Subsection 37(1.1)||SR&ED performed by sub to improve products of unrelated business of parent is deemed to be related to sub’s business|
|26 September 2002 External T.I. 2002-0128955 F - 84.1(1)(b) Deem Dividend 83(2) CDA
rev'd by 11 October 2019 APFF Roundtable, Q.1
|Income Tax Act - Section 83 - Subsection 83(2)||s. 84.1 deemed dividend to someone who in fact was not a shareholder was not eligible for an s. 83(2) election|
|3 October 2002 External T.I. 2002-0133525 F - CADEAUX QUASI-MONETAIRES||Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a)||awards of gifts certificates that could be exchanged for under $500 of the employer’s goods were taxable benefits|