We have translated 8 more CRA interpretations

8 April 2024 - 11:53pm
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We have translated 2 CRA interpretations released last week and a further 6 CRA interpretations released in February of 2002. Their descriptors and links appear below.

These are additions to our set of 2,800 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 22 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
2024-04-03 26 February 2024 External T.I. 2019-0813441E5 F - Frais de scolarité pour un cours par correspondance Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(a) shipping and handling charges for correspondence-course books included in tuition
23 February 2024 External T.I. 2020-0852621E5 F - Pompier volontaire Income Tax Act - Section 118.06 - Subsection 118.06(1) CRA position on “volunteer firefighter” remained in force following Bourgeois
2002-02-01 22 February 2002 Internal T.I. 2001-0095217 F - FAILLITE-PROVINCE DE RESIDENCE Income Tax Act - Section 128 - Subsection 128(2) - Paragraph 128(2)(e) returns for both stub returns for year of bankruptcy are filed for the province of the individual’s residence on December 31 of that calendar year
Income Tax Regulations - Regulation 2601 - Subsection 2601(1) return for short taxation year resulting from bankruptcy required to be filed for the province of the individual’s residence on December 31 of that calendar year
14 February 2002 Internal T.I. 2001-0107757 F - PENSION ALIMENTAIRE POUR ENFANTS Income Tax Act - Section 56.1 - Subsection 56.1(4) - Child Support Amount separation agreement was sufficiently general as to the amounts’ use for them to be child support amounts
Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount fixed support payments were not required to be applied by the recipient to listed expenses and, therefore, their use was at her discretion and they were allowances
21 February 2002 External T.I. 2001-0102405 F - ACTIVITE AGRICOLE-ERABLIERE Income Tax Act - Section 248 - Subsection 248(1) - Farming provision of meals at a sugar shack was a separate non-farming activity
Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property use of maple sugar shack in significant meal preparation operation caused the farm property to not qualify as a “qualified farm property”
20 February 2002 External T.I. 2001-0114745 F - CONTINUATION SOCIETE EN COOPERATIVE Income Tax Act - Section 248 - Subsection 248(1) - Disposition consequences of the continuance of a corporation as a cooperative depend on the implementation details
14 February 2002 External T.I. 2002-0118915 F - BIENS ETRANGERS INTERETS COURUS Income Tax Act - Section 248 - Subsection 248(1) - Cost Amount - Paragraph (b) cost amount of loan does not include accrued interest
20 February 2002 External T.I. 2001-0105695 F - Remboursement d'impôt d'une fiducie liquidée Income Tax Act - 101-110 - Section 104 - Subsection 104(1) ex-trustee rather than ex-unitholders should be paid the tax refund to which wound-up mutual fund trust was entitled