We have translated 7 more CRA severed letters

1 July 2024 - 10:56pm
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We have translated a ruling released last week and a further 6 CRA interpretations released in October of 2001. Their descriptors and links appear below.

These are additions to our set of 2,879 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 ¾ 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
2024-06-26 2024 Ruling 2023-0994301R3 F - Loss consolidation arrangement Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) loss-shifting transactions beneath a non-wholly owning Canadian LP
2001-10-12 29 October 2001 External T.I. 2001-0092035 F - association related persons Income Tax Act - Section 256 - Subsection 256(1.4) - Paragraph 256(1.4)(a) crucially, s. 256(1.4)(a), unlike s. 251(5)(b)(i), deems the affected shares to be issued and outstanding
Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(i) s. 251(5)(b)(i) applies differently than s. 256(1.4)(a) because it does not deem the subject shares to be outstanding
30 October 2001 External T.I. 2001-0070655 F - COMMISSION VENDEUR D'ASSURANCE-VIE Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit commission received by self-employed life insurance broker for the purchase of a policy for his own account, was not taxable unless it was substantial
22 October 2001 External T.I. 2001-0070715 F - ALLOCATIONS AUTOMOBILES Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) car allowance was not a non-taxable advance because it was not required to be repaid if it exceeded the business kilometres
24 October 2001 External T.I. 2001-0074385 F - GAINS ET PERTES EN CAPITAL Income Tax Act - Section 96 - Subsection 96(1.7) numerical illustration of application of s. 6(1.7) formula re increase in capital gains inclusion rate
15 October 2001 External T.I. 2001-0098315 F - PLACEMENT ADMISSIBLE REER Income Tax Regulations - Regulation 4901 - Subsection 4901(2) - Designated Shareholder - Paragraph (d) employees constitute a group if they collectively have control
Income Tax Regulations - Regulation 4901 - Subsection 4901(2.2) - Paragraph 4901(2.2)(b) IT-419, para. 13 re right of first refusal/ shotgun applies to application of Reg. 4901(2.2)(b)
Income Tax Regulations - Regulation 4901 - Subsection 4901(2) - Designated Shareholder - Paragraph (a) IT-419 position re right of first refusal/ shotgun applies to designated shareholder test
23 October 2001 External T.I. 2001-0090295 F - choix de ne plus être une société publique Income Tax Regulations - Regulation 4803 - Subsection 4803(1) - Insider of a Corporation Buyco acquiring all the target shares was an insider of a corporation