We have translated 7 more CRA interpretations

We 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 2,662 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
2023-12-06 17 December 2018 Internal T.I. 2016-0659031I7 F - Attendance of board of directors meeting by phone Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) participation in Canadian board meetings by telephone from outside Canada is not the exercise of the office in Canada
Income Tax Regulations - Regulation 104 - Subsection 104(2) no withholding on directors’ fees from duties not exercised in Canada
2002-07-05 30 July 2002 External T.I. 2002-0121435 F - categorie 16 - remorquage Income Tax Regulations - Schedules - Schedule II - Class 16 - Paragraph 16(g) towing of heavy vehicles and buses constitutes hauling freight
12 July 2002 External T.I. 2002-0127585 F - Legal Expenses, Compensation for Defamation Income Tax Act - Section 3 - Paragraph 3(a) damages received by employee for defamation were tax free if their character not misrepresented
Income Tax Act - Section 5 - Subsection 5(1) damages received by employee for defamation were not employment income if not deliberately mislabeled
Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(b) legal fees incurred for employee to receive damages only for defamation were not deductible
4 July 2002 External T.I. 2002-0130675 F - Sec. 159 - Payments on Behalf of Others Income Tax Act - Section 159 - Subsection 159(2) purchaser’s lawyer not a legal representative of the vendor notwithstanding payment directions received from vendor
19 July 2002 External T.I. 2002-0133535 F - PERTE APPARENTE CALCUL DU PBR Income Tax Act - Section 54 - Superficial Loss numerical illustration where series of partial dispositions, and acquisitions, of identical shares
29 July 2002 External T.I. 2001-007075A F - DEPLACEMENT - TRAVAILLEUR FORESTIER Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) travel between home and forestry camp, but not between forestry camp and cutting sites, generally was personal
19 June 2002 External T.I. 2002-0120035 F - Non Arm's Length Corporations Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(c) - Subparagraph 251(2)(c)(ii) 2 brothers’ respective corporations were related