We have translated 7 more CRA interpretations
4 December 2023 - 11:12pm
Email this ContentWe have translated a CRA interpretation released last week and 6 further CRA interpretations released during July of 2002. Their descriptors and links appear below.
These are additions to our set of 2,655 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 1/3 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 |
|---|---|---|---|
| 2023-11-29 | 4 October 2023 Internal T.I. 2020-0837811I7 F - Suspended loss | Income Tax Act - Section 40 - Subsection 40(3.5) - Paragraph 40(3.5)(c) - Subparagraph 40(3.5)(c)(i) | suspended loss rule continued to apply when the transferee was amalgamated, then wound-up into the transferor |
| Income Tax Act - Section 251.1 - Subsection 251.1(4) - Paragraph 251.1(4)(a) | corporation in its 2 capacities of transferor, and continuation of transferee, was affiliated with itself | ||
| 2002-07-19 | 6 August 2002 Internal T.I. 2002-0130897 F - RECOMPENSES ES QUASI-MONETAIRES | Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(l) - Subparagraph 18(1)(l)(ii) | s. 18(1)(l)(ii) applies irrespective whether the membership is an employer gift within the ITTN 25 gifts policy |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | gift cards and smart cards with spendable balances do not come within the ITTN 25 gifts policy | ||
| Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(d) | s. 67.1(2)(d) exclusion inapplicable to meal or show ticket gifts within ITTN 25 gifts policy | ||
| 9 August 2002 Internal T.I. 2002-0145817 F - TAUX DE DEDUCTION - PTPE - ANNEE 2000 | Income Tax Act - Section 38 - Paragraph 38(c) | BIL realized under s. 50 at end of year (2000) so that ½ an ABIL | |
| 2 August 2002 External T.I. 2002-0152445 F - RENTE VIAGERE ET CREDIT | Income Tax Act - Section 118 - Subsection 118(7) - Pension Income - Paragraph (a) - Subparagraph (a)(i) | an annuity that ceases upon attaining a specified age is not a “life annuity” | |
| 13 August 2002 External T.I. 2002-0121295 F - PBR DES PARTS PRIVILEGIEES | Income Tax Act - Section 43 - Subsection 43(1) | sale of preferred and retention of common partnership units entailed part disposition of single property/ different s. 43 allocation methods possible | |
| Income Tax Act - Section 248 - Subsection 248(1) - Property | preferred and common partnership units were single property | ||
| 6 August 2002 External T.I. 2002-0130735 F - DISPOSITION D'UN PERMIS | Income Tax Regulations - Schedules - Schedule II - Class 14 | licence to operate a seniors home was eligible capital property whereas related agreements with Ministry (that after a point were not automatically renewable) were Class 14 property | |
| 2002-07-05 | 31 July 2002 External T.I. 2002-0153135 F - FRAIS JUDICIAIRES | Income Tax Act - Section 60 - Paragraph 60(o.1) | amounts incurred by retiree association in suing pension fund not deductible under s. 60(o.1) unless incurred as agent for retirees |