We have translated 6 more CRA interpretations

15 January 2024 - 11:36pm
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We have translated 6 further CRA interpretations released during May of 2002. Their descriptors and links appear below.

These are additions to our set of 2,694 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 3/4 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
2002-05-24 6 June 2002 External T.I. 2002-0133895 F - entreprise de placement determinee Income Tax Act - Section 125 - Subsection 125(7) - Specified Investment Business recapture from sale of a rental business qualified as business income that was not from a specified investment business, notwithstanding no employees in that year after the sale
Income Tax Act - Section 13 - Subsection 13(1) recapture is treated as income from the business in which the depreciable asset was used
27 May 2002 External T.I. 2002-0135605 F - DIVISION 6208(1)a)(iii)(A) du Règlement Income Tax Regulations - Regulation 6208 - Subsection 6208(1) - Paragraph 6208(1)(a) - Subparagraph 6208(1)(a)(iii) meaning of “other property” informed by s. 248(1) meaning of “property”
10 June 2002 External T.I. 2002-0138885 F - Redemption of Preferred Shares Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) s. 55(3)(a) applicable to redemption by Opco of preferred shares held by father’s holding company where Opco’s common shares held by his children or their Holdcos
4 June 2002 External T.I. 2002-0141435 F - Disposition of Shares Income Tax Act - Section 248 - Subsection 248(1) - Disposition exchange of voting common for voting pref and non-voting common is a disposition
Income Tax Act - Section 85 - Subsection 85(1) exchange of voting common for voting pref and non-voting common eligible for s. 85(1) election
12 June 2002 External T.I. 2002-0143325 F - REGIME DE CONGE A TRAITEMENT DIFFERE Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(a)(ii) combined application of 33 1/3% limit where 2 SDAs
Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(a)(iii) where 2 SDAs, combined application of reduction under Reg. 6801(a)(iii)(A)
24 May 2002 Internal T.I. 2002-0130667 F - REGIME PRESTATION EMPLOYES Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement discussion of transitional rules re expansion of SDA rules effective February 26, 1986
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(g) amounts received by retiring employee under EBP even if elected not to receive
General Concepts - Payment & Receipt amounts “received” under EBP if unrestricted right to receive