We have translated 6 more CRA interpretations

10 June 2024 - 11:50pm
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We have translated a further 6 CRA interpretations released in November and October of 2001. Their descriptors and links appear below.

These are additions to our set of 2,858 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
2001-11-23 21 November 2001 Internal T.I. 2001-0094527 F - PERTE REPUTEE NULLE-BRYAN Income Tax Act - Section 50 - Subsection 50(1) - Paragraph 50(1)(a) no partial bad debt recognition under s. 50(1)(a)
Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) Byram now followed re loss on non-interest-bearing shareholder loan to corporation
16 November 2001 Internal T.I. 2001-0095617 F - ACCORD ECRIT RETROACTIF GARDE D'ENFANTS Income Tax Act - Section 118 - Subsection 118(5) subsequent letter was not an agreement eliminating a support obligation in respect of one of the two children
Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount “agreement” must correspond “to the reality of a situation of shared financial and parental responsibilities and … [be] a valid contract … creating mutual obligations”
2001-11-09 21 November 2001 External T.I. 2000-0062895 F - BOURSE D'ETUDES OU REVENU D'EMPLOI Income Tax Act - Section 5 - Subsection 5(1) “scholarships” that had to be repaid if the student did not then work for the employer were received qua employee – but could be non-taxable as primarily for employer’s benefit
9 November 2001 External T.I. 2001-0101685 F - APPLICATION DE 16.1 ET DE 85(1) Income Tax Act - Section 85 - Subsection 85(1) a property for which an s. 16.1(1) election has been made cannot be transferred on a rollover basis under s. 85(1)
Income Tax Act - Section 16.1 - Subsection 16.1(1) - Paragraph 16.1(1)(f) s. 16.1(1)(f) does not accommodate an s. 85(1) disposition to a corporation
21 November 2001 External T.I. 2001-0104785 F - CONTRIBUTION A UN RPA SERVICES PASSES Income Tax Act - Section 147.2 - Subsection 147.2(4) - Paragraph 147.2(4)(c) counts as a service year even if only one day of services
2001-10-26 16 November 2001 External T.I. 2000-0054435 F - BIENS AGRICOLES ADMISSIBLES Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Interest in a Family Farm or Fishing Partnership - Paragraph (a) ownership of the farm operating corporation by the partnership meant that the partnership interests were not qualified farm property