We have translated 7 more CRA interpretations

29 April 2024 - 11:26pm
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We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in January of 2002. Their descriptors and links appear below.

These are additions to our set of 2,819 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
2024-04-24 7 October 2021 Roundtable, 2021-0908201C6 F - Vente d'un bien détenu en copropriété par indivisi Income Tax Act - Section 74.2 - Subsection 74.2(1) imputation of an inter-spousal gift or loan on spouses’ property purchase (based on how the sales proceeds were agreed to be shared) engaged s. 74.2(1)
2002-01-18 11 February 2002 Internal T.I. 2001-0102747 F - FABRICATION ET TRANSFORMATION Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits not sale of products where services component of construction contract was not incidental
Income Tax Act - Section 9 - Timing contract completion method can be used by a non-construction business company
Income Tax Act - Section 125.1 - Subsection 125.1(3) - Manufacturing or Processing - Paragraph (c) M&P activity not assimilated to construction business where half the gross revenues were from sales
3 December 2001 Internal T.I. 2001-0104677 F - VERSEMENT POUR REMBOURSER L'IMPOT Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount annual top-up to monthly support to cover income tax to the recipient qualified as support amount
5 December 2001 Internal T.I. 2001-0089247 F - CDC - Immobilisation Admissible Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (c.1) CDA addition for completed taxation years/ no double ECE deduction
22 January 2002 Internal T.I. 2001-0100537 F - ENTENTE TEMPORAIRE PENSION ALIMENTAIRE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day cessation of temporary support variation agreement would effectively reverse the commencement day
8 February 2002 Internal T.I. 2001-0106197 F - PRIME D'ASSURANCE-VIE Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) allocation of premium between plan with different components
14 December 2001 Internal T.I. 2001-0114320 F - CADEAUX ON RECOMPENSES Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) new gift policy does not apply to gifts made to shareholders or their family members