We have translated 8 more CRA severed letters
5 February 2024 - 10:58pm
Email this ContentWe have translated 2 translations of a CRA interpretation and ruling issued last week and a 6 further CRA interpretations released during April of 2002. Their descriptors and links appear below.
These are additions to our set of 2,718 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 |
|---|---|---|---|
| 2024-01-31 | 2023 Ruling 2022-0955451R3 F - Post mortem pipeline | Income Tax Act - Section 84 - Subsection 84(2) | conventional post-mortem pipeline transaction |
| 22 June 2023 External T.I. 2018-0746741E5 F - Eligible dividend allocation | Income Tax Act - 101-110 - Section 104 - Subsection 104(19) | eligible and non-eligible dividend can be wholly designated to two respective beneficiaries | |
| Income Tax Act - 101-110 - Section 104 - Subsection 104(13) | a discretionary trust can wholly allocate each of an eligible and a non-eligible dividend to each of two recipient beneficiaries | ||
| 2002-04-26 | 22 May 2002 Internal T.I. 2001-0106577 F - APPARIEMENT DES REVENUS ET DEPENSES | Income Tax Act - Section 9 - Timing | following Canderel, an upfront payment made under a multi-year supply contract is currently deductible |
| 14 May 2002 Internal T.I. 2001-0109517 F - SECTION DE LA LOI248(28) | Income Tax Act - Section 248 - Subsection 248(28) | disallowance of interest deduction to partnership on loans to corporate partners whose amount was included in their income under s. 15(2), was not contrary to s. 248(28) | |
| 8 May 2002 Internal T.I. 2002-0135737 F - REGIME DE CONGE A TRAITEMENT DIFFERE | Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(a)(vi) | s. 6(11) income recognition when apparent that the leave would not commence within 6 years/ Reg. 6801(a)(vi) does not to extend 6-year period but deals with leaves over one year | |
| 2002-04-12 | 3 May 2002 External T.I. 2001-0110145 F - avantage imposable-vetements | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | reimbursing a professor for a briefcase needed in connection with work would be non-taxable |
| 3 May 2002 External T.I. 2002-0132615 F - PERTE DECOULANT D'UN PAIEMENT A UN RPDB | Income Tax Act - Section 147 - Subsection 147(8) | creation of a business loss from making a DPSP contribution is not necessarily inconsistent with the DPSP rules | |
| 1 May 2002 External T.I. 2002-0133145 F - RAP - BAIL & ACTIONS | Income Tax Act - Section 146.01 - Subsection 146.01(1) - Qualifying Home | unit consisting of a leasehold interest and shares of the corporation owing the property could qualify as qualifying home |