We have translated 8 more CRA interpretations

3 June 2024 - 11:07pm
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We have translated 2 interpretations released by CRA last week and a further 6 CRA interpretations released in November of 2001. Their descriptors and links appear below.

These are additions to our set of 2,852 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 2/3 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
2024-05-29 14 March 2024 External T.I. 2015-0596761E5 F - Traitement fiscal Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense expenditure on anti-theft marking of car likely would be on current account
Income Tax Act - Section 18 - Subsection 18(9) practice is not to apply s. 18(9) where the adjustments would be minimal
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(k) - A - Subparagraph A(iv) mandatory requirement for employee notification to employer by end of year
4 April 2024 External T.I. 2023-0996201E5 F - Employment income to sole shareholder Other Legislation/Constitution - Federal - Indian Act - Section 87 the salary of a status Indian from his corporation may be exempted based on the relative sourcing of its income on and off reserve
2001-11-23 6 November 2001 External T.I. 2000-0029615 F - revenu protégé en main Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) safe income shortly before a stub year end reduced by s. 111(5.1) write-down at the end of that stub year
15 November 2001 External T.I. 2001-0088285 F - deferral of gain on involuntary dispositions Income Tax Act - Section 44 - Subsection 44(1) s. 44(1) rollover might be saved where the insurance proceeds for the 1st replaced building are not deemed as received until after receipt of insurance proceeds for the 2nd replaced building
28 November 2001 External T.I. 2001-0104285 F - PRESTATION CONSECUTIVE AU DECES Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit death benefit paid to widow is not income
Income Tax Act - Section 3 - Paragraph 3(a) lump sum death benefit paid by employer to widow of deceased employee, not income
6 November 2001 External T.I. 2001-0105945 F - INTERETS LUDCO SINGLETON Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) scope of study on impact of Ludco and Singleton
7 December 2001 External T.I. 2001-0107765 F - RPA-ALLOCATION DE RETRAITE Income Tax Act - Section 60 - Paragraph 60(j.1) - Subparagraph 60(j.1)(iii) - Clause 60(j.1)(iii)(A) amount deductible under s. 8(1)(m) cannot be included in the amount deducted under s. 60(j.1)(iii)(A),
6 December 2001 External T.I. 2001-0113375 F - PLACEMENT REER NASDAQ Income Tax Regulations - Regulation 4900 - Subsection 4900(1) - Paragraph 4900(1)(s) no deemed acquisition if pink-sheet stock is held after December 31, 2001, but tax on FMV at actual acquisition time applies