We have translated 6 more CRA interpretations
22 January 2024 - 11:30pm
Email this ContentWe have translated 6 further CRA interpretations released during May of 2002. Their descriptors and links appear below.
These are additions to our set of 2700 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 |
|---|---|---|---|
| 2002-05-10 | 24 May 2002 External T.I. 2002-0123225 F - REER DONNE EN GARANTIE | Income Tax Act - Section 146 - Subsection 146(8) | generally no double taxation under s. 146(8) on payout on guarantee if property’s value previously included under s. 146(10)/ gross-up for source deduction purposes |
| Income Tax Act - Section 146 - Subsection 146(10) | inclusion under s. 146(10) for secured guarantee not limited to loan value, and ousts application of s. 146(8) if payment made by RRSP pursuant to guarantee | ||
| Income Tax Act - Section 248 - Subsection 248(28) | s. 248(28) prevents double inclusion under s. 146(10) when secured guarantee given and under s. 146(8) when guarantee called | ||
| 24 May 2002 Internal T.I. 2001-0113597 F - ASSURANCE CONTRE LES MALADIES GRAVES | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) | if a clause providing for the return of premiums on death was ancillary, the policy could still qualify as a group sickness or accident insurance plan | |
| 20 May 2002 External T.I. 2002-0117885 F - Lien de dépendance et application de 120.4 | Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(a) | trustee is related to individual if its trustee is so related | |
| Income Tax Act - Section 120.4 - Subsection 120.4(1) - Split Income - Paragraph (c) | split income definition applied on the basis that the business of a partnership is carried on by its partners and that a trust if related based on the relatedness of its trustee | ||
| Income Tax Act - 101-110 - Section 104 - Subsection 104(1) | s. 104(1) indicates that related party status of trust is tested through its trustee | ||
| 2 May 2002 External T.I. 2002-0134335 F - Sous-aliéna 104(4)a)(i) et 110.6(15)a)(i) | Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(15) - Paragraph 110.6(15)(a) - Subparagraph 110.6(15)(a)(i) | s. 110.6(15)(a)(i) deeming rule does not apply for s. 104(4)(a)(i) purposes | |
| 15 May 2002 External T.I. 2001-0103605 F - Prêt par un Associé à une Société | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) | interest on loan by partner to partnership is treated as interest rather than income allocation if there is a loan rather than partnership contribution under provincial law | |
| Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(g) | if a loan made by a partner is at law a loan rather than a partnership contribution, the interest thereon will be treated as interest rather than profit allocation | ||
| 31 May 2002 External T.I. 2001-0110095 F - ALLOCATIONS NON IMPOSABLES | Income Tax Act - Section 6 - Subsection 6(16) - Paragraph 6(16)(a) | mobility impairment means significant difficulty moving around that lasts 12 months |