We have translated 6 more CRA interpretations

22 April 2024 - 9:45pm
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We have translated a further 6 CRA interpretations released in January of 2002. Their descriptors and links appear below.

These are additions to our set of 2,812 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 ¼ 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
2002-01-18 11 January 2002 External T.I. 2001-0112605 F - Section 159 - Payments on behalf of others159(2) Income Tax Act - Section 159 - Subsection 159(2) payment of purchase price by purchaser to trust account of its lawyer or purchaser’s lawyer for discharge first of non-CCRA debts did not engage s. 159(2)
Income Tax Act - Section 248 - Subsection 248(1) - Legal Representative establishment for the purchaser of a trust account to pay vendor’s debts did not render it a legal representative of the vendor
10 January 2002 External T.I. 2001-0112885 F - ASSURANCE-VIE ET PRET REMBOURSE AU DECES Income Tax Act - Section 148 - Subsection 148(9) - Policy Loan GAAR could apply where a life insurance policy is pledged for a loan that is not required to be repaid until after death
Income Tax Act - Section 15 - Subsection 15(1) benefit may result from pledging a corporate asset to secure a personal loan
Income Tax Act - Section 207.6 - Subsection 207.6(2) overview of employer use of life insurance policy to fund RCA benefits
28 January 2002 External T.I. 2002-0116635 F - REEE-REGLE D'ATTRIB. ET PERT NULLE Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) s. 40(2)(g) does not apply on a transfer to an RESP
Income Tax Act - Section 74.3 - Subsection 74.3(1) - Paragraph 74.3(1)(a) s. 74.1(2) does not apply where a taxpayer transfers property to an RESP
14 January 2002 External T.I. 2001-0114035 F - ECHANGE D'ACTIONS ET PARAGRAPHE 9001(2) Income Tax Regulations - Regulation 9001 - Subsection 9001(2) - Paragraph 9001(2)(a) shares will remain prescribed shares if the corporation ceases to be a QSBC after one year
Income Tax Regulations - Regulation 9001 - Subsection 9001(2) - Paragraph 9001(2)(b) share exchange must be with the original share issuer
25 January 2002 External T.I. 2001-0114615 F - CONTRAT DE RENTE PRESCRITE ET FIDUCIE Income Tax Regulations - Regulation 304 - Subsection 304(3) - Paragraph 304(3)(a) a beneficiary of a trust holding an annuity contract is not necessarily deemed to be the annuitant
Income Tax Regulations - Regulation 304 - Subsection 304(1) - Paragraph 304(1)(c) - Subparagraph 304(1)(c)(iv) - Clause 304(1)(c)(iv)(B) requirement of fixed term where holder is a trust other than under s. 104(4)(a)
14 January 2002 External T.I. 2001-0116225 F - DOMMAGE SUBI PAR UN REER ET INDEMNITE Income Tax Act - Section 146 - Subsection 146(1) - Premium payment by broker of damages to RRSP was not a premium
Income Tax Act - Section 146 - Subsection 146(8) payment by broker of damages to RRSP was not a benefit to annuitant