We have translated 6 more CRA interpretations

29 July 2024 - 11:11pm
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We have translated a further 6 CRA interpretations released in September of 2001. Their descriptors and links appear below.

These are additions to our set of 2,904 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
2001-09-28 13 September 2001 External T.I. 2001-0097675 F - COUT INDIQUE REVENUS A RECEVOIR Income Tax Act - Section 248 - Subsection 248(1) - Cost Amount - Paragraph (b) cost amount of shares not increased by dividend receivable, and of loan, not increased by accrued interest
30 August 2001 External T.I. 2001-0093645 F - FRAIS IMPUTE A UN REER LORS D'UN RETRAIT Income Tax Act - Section 146 - Subsection 146(8) no annuitant benefit where RRSP bears an admin fee on a withdrawal
23 August 2001 External T.I. 2001-0095015 F - ALLOCATION DE RETRAITE Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance retiring allowance can be received in instalments and well in advance of planned termination date
18 September 2001 External T.I. 2001-0095265 F - TAXE SUR LE CAPITAL Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(c) outstanding cheques are not loans or advances, but they reduce the debts of which they are repayment only to the extent reflected in the balance sheet
General Concepts - Payment & Receipt in Quebec, a cheque is not payment until the debtor’s account is debited
17 August 2001 External T.I. 2001-0095645 F - PRET HYPOTHECAIRE INTERETS Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) administratively splitting a mortgage loan into 2 components does not allow the principal repayments to be allocated first to repayment of the loan’s ineligible portion
29 August 2001 External T.I. 2001-0097485 F - DEDUCTION DE FRAIS DE SURVEILLANCE Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) supervisory fees paid to intermediary between portfolio manager and taxpayer were non-deductible