We have translated 6 more CRA interpretations

19 August 2024 - 11:23pm
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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 2,922 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 17 July 2001 External T.I. 2001-0068355 F - DEDUCTION D'UN BONI A UN EMPLOYE Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) bonus paid to manage investments would not be a disposition expense
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Oversight or Investment Management investment performance bonus to be deductible would need to be incurred as part of the activity of managing the investments
2 May 2001 Internal T.I. 2001-007939 F - CONVENTION D'EMISSION D'ACTIONS Income Tax Act - Section 7 - Subsection 7(2) whether s. 7(2) applied turned on whether shares were held as trustee
2001-09-14 31 August 2001 External T.I. 2000-0062435 F - CREDIT EQUIVALENT-PENSION ALIMENTAIRE Income Tax Act - Section 118 - Subsection 118(5) - Paragraph 118(5)(a) s. 118(5)(a) precluded s. 118(1)(b) credit for joint-custody child where support paid
19 September 2001 External T.I. 2001-0070815 F - REVENU OF SOCIETES DE PERSONNES Income Tax Act - 101-110 - Section 103 - Subsection 103(1) valid non-tax reason for allocating gains on shares differently than dividends would need to be established
17 September 2001 External T.I. 2001-0098635 F - Spin-off - T5 Income Tax Act - Section 86.1 - Subsection 86.1(2) general overview re US spin-off
Income Tax Act - Section 248 - Subsection 248(1) - Amount amount of dividend-in-kind (e.g., a spin-off that does not qualify under s. 86.1) is the FMV of the distributed shares
18 September 2001 External T.I. 2001-0100485 F - PARTAGE D'ACTION DETENUE EN INDIVISION Income Tax Act - Section 248 - Subsection 248(21) no need to issue fractional share certificates on partition of shares held in co-ownership for s. 248(21) to apply/ no disposition on subsequent global certificate issuance
Income Tax Act - Section 248 - Subsection 248(20) s. 248(20) produced the same results as s. 248(21)