We have translated 6 more CRA interpretations

16 September 2024 - 11:13pm
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We have translated a further 6 CRA interpretations released in August and July of 2001. Their descriptors and links appear below.

These are additions to our set of 2,946 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
2001-08-17 12 July 2001 Internal T.I. 2001-0089347 F - PRESTATION DE DÉCES Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a.1) QPP death benefit paid directly to an individual was not taxable
11 July 2001 External T.I. 2001-0078365 F - APPLICATION DE 75(2) ET 104(4) Income Tax Act - Section 75 - Subsection 75(2) - Paragraph 75(2)(a) - Subparagraph 75(2)(a)(i) s. 75(2) applies where transferor can receive taxable capital gains distributions
Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(a) deemed disposition date for "joint spousal or common-law partner trust" is the later of date of death of settlor and settlor's spouse/ common-law partner, irrespective of being "spousal trust"
2001-07-20 19 June 2001 Internal T.I. 2000-0062787 F - FRAIS JURIDIQUES-GARANTIE Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees promissory notes to bank were given to preserve an investment, so that legal fees incurred to avoid paying on the notes were capital expenditures
4 July 2001 External T.I. 2001-0068885 F - Entreprise Exploitée Activement Income Tax Act - Section 125 - Subsection 125(7) - Active Business Carried On by a Corporation auto-leasing corporation had an active business
6 July 2001 External T.I. 2001-0086775 F - SOCIETE A CAPITAL DE RISQUE Income Tax Act - Section 204.81 - Subsection 204.81(1) - Paragraph 204.81(1)(c) - Subparagraph 204.81(1)(c)(vii) - Clause 204.81(1)(c)(vii)(C) transfer of LSVCC Class A share to the RRSP of transferor’s spouse would not result in recapture of the tax credit
5 July 2001 External T.I. 2001-0089105 F - ECHANGE D"OPTIONS - COUT INDIQUE Income Tax Act - Section 85 - Subsection 85(1) RRSP may make a s. 85(1) election