We have translated 8 more CRA severed letters

We 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