We have translated 6 more CRA interpretations

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 2,825 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 1/3 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
2002-01-04 9 January 2002 External T.I. 2001-0089655 F - AVANTAGE AUTOMOBILE Income Tax Act - Section 248 - Subsection 248(1) - Automobile - Paragraph (e) - Subparagraph (e)(i) 6-seat pickup not excluded from 90% test
Income Tax Act - Section 6 - Subsection 6(2) being on-call at home does not diminish the personal benefit from use
10 January 2002 External T.I. 2001-0090325 F - UTILISATION DES VEHICULES Income Tax Act - Section 6 - Subsection 6(2) commuting in connection with employer requirement to keep vehicle overnight at home was personal use – but not emergency use
18 January 2002 External T.I. 2001-0092665 F - AUTOMOBILE-VEHICULE PUBLICITAIRE Income Tax Act - Section 248 - Subsection 248(1) - Automobile automobile status turns on design, not use (here, only for advertising)
Income Tax Act - Section 248 - Subsection 248(1) - Automobile - Paragraph (e) - Subparagraph (e)(i) vehicle cosmetically altered for advertising purposes is not thereby used to transport goods or equipment
8 January 2002 External T.I. 2001-0094485 F - EMPLOI SUR UN CHANTIER PARTICULIER Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) s. 6(6) applicable to a non-citizen
21 January 2002 External T.I. 2001-0078735 F - Droit de recevoir une somme Income Tax Act - Section 54 - Proceeds of Disposition FMV of contingent right to deferred cash sales proceeds was included in proceeds, with subsequent gain or loss when the contingency was resolved
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) s. 12(1)(g) inapplicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration declined in value
Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(f) s. 85(1)(f) applicable to contingent right to receive deferred cash sales proceeds to the extent the share consideration received under s. 85(1) declined in value
21 January 2002 External T.I. 2001-0080325 F - FRAIS DE VOYAGE-BIENS LOCATIFS Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) notwithstanding s. 18(1)(h) jurisprudence, CCRA allows travel expenses incurred for collecting rent, supervising repair work or managing the multiple rental properties