We have translated 6 more CRA interpretations

9 September 2024 - 11:18pm
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We have translated a further 6 CRA interpretations released in September and August of 2001. Their descriptors and links appear below.

These are additions to our set of 2,940 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 23 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 25 April 2001 Internal T.I. 2000-0060537 F - DATE D'EXECUTION=JUGEMENT TEMPORAIRE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day temporary judgment had a commencement day, but on its cancellation by a final judgment, the pre-May. 1997 status of the initial judgment may have been restored
7 June 2001 Internal T.I. 2000-0060747 F - PROPOSITION CONCORDATAIRE - PTPE Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (b) - Subparagraph (b)(ii) discharge of unsecured debt owing to debtor’s shareholder under bankruptcy proposal was a disposition
Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) non-interest-bearing advances made by shareholder for income-producing purpose given Byram
28 February 2001 Internal T.I. 2000-0061667 F - COTIDATIONS-ALLOC. FIN DE CARRIERE Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(i) - Subparagraph 8(1)(i)(i) professional dues not deductible from end-of-career allowance received by physician
Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(i) - Subparagraph 8(1)(i)(iii) union dues paid to the Quebec doctors’ federations were deductible from retirement allowances received as business income but not as retiring allowances
Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance end-of-career allowance was retiring allowance
11 June 2001 Internal T.I. 2001-0074867 F - Définition de gains exonérés pré-96 Income Tax Regulations - Regulation 5907 - Subsection 5907(1) - Exempt Earnings “resides” in the pre-1976 exempt earnings definition referenced central management and control
Income Tax Regulations - Regulation 5907 - Subsection 5907(11.2) Barbados exempt insurance company is deemed not to be resident in Barbados
24 May 2001 Internal T.I. 2000-0047827 F - PENSION ALIMENTAIRE-CLAUSE RETROACTIVE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day - Paragraph (a) subsequent judgment that varied support in divorce judgment caused a commencement day/ retroactive effective date of consent judgment not respected
General Concepts - Effective Date consent judgment that purported to be retroactive did not have retroactive effect
Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount payment of arrears of periodic support would be periodic support under the related pre-May 1997 consent judgment
2001-08-17 10 August 2001 External T.I. 2001-0084945 F - application des para. 73(1.01) et (1.02) Income Tax Act - Section 73 - Subsection 73(1.02) - Paragraph 73(1.02)(b) - Subparagraph 73(1.02)(b)(ii) application of s. s. 73(1.02)(b)(ii) to Quebec trust under review