We have translated 10 more CRA interpretations

29 January 2024 - 11:13pm
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We have translated 4 translations of CRA interpretations issued last week and of a 6 further CRA interpretations released during May and April of 2002. Their descriptors and links appear below.

These are additions to our set of 2,710 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
2024-01-24 21 December 2023 External T.I. 2016-0654081E5 F - Transfer of life insurance
2020-0866651E5 F is similar
21 December 2023 External T.I. 2019-0822121E5 F - Transfer of life insurance policy from a trust to
2020-0866651E5 F is similar
21 December 2023 External T.I. 2020-0866651E5 F - Transfer of life insurance Income Tax Act - Section 148 - Subsection 148(7)
2016-0654081E5 F and 2019-0822121E5 F are similar

a trust distribution of a life insurance policy to a beneficiary treated as being made for FMV consideration equal to the part of the beneficiary’s capital or income interest that is satisfied
3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 2, 2023-0978631C6 F - CELIAPP - Autoconstruction d'une habitation - FHSA - Self-construction Income Tax Act - Section 146.6 - Subsection 146.6(1) - Qualifying Withdrawal - Paragraph (a) acquisition of home is when it becomes habitable
Income Tax Act - Section 146.6 - Subsection 146.6(1) - Qualifying Withdrawal - Paragraph (c) written agreement for construction before October 1 could be satisfied with agreements with trades by self-constructing individual
2002-05-10 9 May 2002 Internal T.I. 2002-0135307 F - Application du paragraphe 39(2) Income Tax Act - Section 90 - Subsection 90(3) distribution of contributed surplus by Delaware subsidiary likely was a dividend
Income Tax Act - Section 39 - Subsection 39(2) distribution by Delaware subsidiary that did not result in s. 40 application thereby did not engage s. 39(2)
Income Tax Act - Section 248 - Subsection 248(1) - Dividend a dividend is any corporate distribution other than of PUC
2002-04-26 15 May 2002 External T.I. 2001-0107805 F - PLUSIEURS ENTREPRISES Income Tax Act - Section 98 - Subsection 98(5) where the terminated partnership carried on more than one business, s. 98(5) requires the sole proprietor to carry on all of those businesses
Statutory Interpretation - Interpretation Act - Subsection 33(2) reference to “the” business included all the businesses
14 May 2002 External T.I. 2001-0105925 F - TOTALITE DES ACTIFS DE L'ENTREPRISE General Concepts - Illegality in 1996, the transfer of inventories of a Quebec pharmaceutical business to a wholly-owned corporation would have been invalid
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(f) - Subparagraph 110.6(14)(f)(ii) - Clause 110.6(14)(f)(ii)(A) unclear whether pharmaceuticals inventory could be transferred to a corporation owned by a pharmacist
17 May 2002 External T.I. 2001-0107815 F - APPLICATION DE LA LOI Income Tax Act - Section 34.1 - Subsection 34.1(8) s. 34.1(8) would apply if an old partnership is replaced by a new one, provided no tax avoidance motivation
Income Tax Act - Section 96 s. 249.1(1) overrode the normal perspective that the partnership business was carried on by the partners both before and after a new partnership was formed
21 May 2002 External T.I. 2002-0133105 F - COUT DES ACTIONS Income Tax Act - Section 112 - Subsection 112(5.2) - Variable B s. 47(1) does not apply to determine the loss on mark-to-market property shares for the purposes of B in s. 112(5.2)
21 May 2002 External T.I. 2001-0097215 F - DISPOSITION D'UN BIEN EN IMMOBILISATION Income Tax Act - Section 248 - Subsection 248(1) - Disposition disposition of land when sold by municipality for unpaid property taxes