We have translated 7 more CRA interpretations

We have translated an interpretation 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 2,886 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
2024-07-03 21 December 2022 Internal T.I. 2019-0826411I7 - Classification of a Burkina Faso SARL Income Tax Act - Section 248 - Subsection 248(1) - Corporation a Burkina Faso S.A.R.L. is a corporation rather than partnership
Income Tax Act - Section 96 a Burkina Faso S.A.R.L. is more akin to a Canadian corporation than partnership
2001-10-12 2 August 2001 External T.I. 2001-0074575 F - Désignation - Validité Income Tax Act - Section 88 - Subsection 88(1) - Paragraph 88(1)(d) overstatement of designation due to misestimate does not invalidate the designation
27 June 2001 Internal T.I. 2001-0084627 F - Crédit d'impôt pour emploi à l'étranger Income Tax Act - Section 248 - Subsection 248(1) - Business to be a business, there need not be a predominant purpose of earning a profit
30 July 2001 External T.I. 2001-0091655 F - Produit de Disposition pour Action Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (a) proceeds of disposition on share-for-share exchange were the stipulated fixed sale price rather than the FMV of the received shares, absent rollover treatment
16 October 2001 Internal T.I. 2001-0095967 F - revenu protégé en main Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) premium paid on open-market repurchases of a corporation’s shares did not reduce the safe income on hand of its remaining shares
10 October 2001 Internal T.I. 2001-0097597 F - Emprunt auprès d'une banque étrangère Income Tax Act - Section 214 - Subsection 214(15) - Paragraph 214(15)(b) setup fees came within s. 214(15)(b)
23 October 2001 Internal T.I. 2001-0102337 F - MONTANTS RECUS D'UNE EGLISE Income Tax Act - Section 3 - Paragraph 3(a) donations received by an evangelist from a foreign church in order to found and build up a Canadian church were taxable