We have translated 6 more CRA interpretations

26 August 2024 - 10:41pm
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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 2,928 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
2001-09-14 27 July 2001 External T.I. 2001-0090305 F - PENALITE-REMBOURSEMENT D'UN EMPRUNT Income Tax Act - Section 18 - Subsection 18(9.1) overview of requirements under s. 18(9.1)
30 August 2001 External T.I. 2000-0058425 F - FRAIS DE DEPLACEMENT Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii.1) travel expense allowances received to preside at municipal court sessions might not be taxable
Income Tax Act - Section 5 - Subsection 5(1) allowances for time spent travelling would be taxable
19 July 2001 External T.I. 2001-0064315 F - OUTILS-TRAVAILLEURS FORESTIERS Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(i) - Subparagraph 8(1)(i)(iii) costs of tools (other than power saws) cannot be deducted under s. 8(1)(i)(iii)
23 August 2001 External T.I. 2001-0086235 F - CONVENTIONS FISCALES A.18 Treaties - Income Tax Conventions - Article 18 QPP and OAS were pension payments made under social security legislation for purposes of the Slovenia and Croatia treaties
Other Legislation/Constitution - Federal - Income Tax Conventions Interpretation Act - Section 5 - Pension - Paragraph (a) - Subparagraph (a)(ix) OAS and QPP payments were “pension” payments
20 July 2001 External T.I. 2001-0087205 F - BAIL TRAITEMENT DU PRENEUR Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition - Paragraph (a) distinction between a sale and a lease is based on whether legally there is a sale or lease
Income Tax Regulations - Regulation 1102 - Subsection 1102(5) whether a lessee has ownership of a building under an emphyteutic lease is a question of law
General Concepts - Substance distinction between a sale and a lease is based on the legal terms of the arrangement
31 August 2001 External T.I. 2001-0087865 F - Accélération de remise de capital Income Tax Act - 101-110 - Section 107 - Subsection 107(2.1) generally favourable consequences of early termination of spousal trust pursuant to s. 107(2.1)
Income Tax Act - 101-110 - Section 106 - Subsection 106(3) no income on redemption of income interest in spousal trust for cash