We have translated 6 more CRA interpretations

23 September 2024 - 11:36pm
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We have translated a further 6 CRA interpretations released in July and June of 2001. Their descriptors and links appear below.

These are additions to our set of 2,952 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
2001-07-20 17 April 2001 Internal T.I. 2001-0064567 F - SPCC-PARTHENON Income Tax Act - Section 256 - Subsection 256(6.1) Parthenon followed re intermediate public corp prior to effective date of s. 256(6.1)
2 May 2001 Internal T.I. 2001-0065497 F - COMMANDITAIRE-RS&DE Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(g) - Subparagraph 96(1)(g)(ii) limited partner not entitled to deduct loss from LP’s SR&ED expenditures
Income Tax Act - Section 127 - Subsection 127(8) - Paragraph 127(8)(b) limited partner not entitled to ITC re LP’s SR&ED expenditures
29 May 2001 Internal T.I. 2000-0053257 F - COOPERATIVE Income Tax Act - Section 136 - Subsection 136(2) - Paragraph 136(2)(c) non-member individual cannot look through a farming member partnership
Income Tax Act - Section 136 - Subsection 136(2) - Paragraph 136(2)(d) shares need not be fully paid
16 May 2001 Internal T.I. 2001-0065277 F - FRAIS DE DÉPLACEMENT D'UN EMPLOYÉ Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) earning income for the employer is the requisite purpose
Income Tax Act - Section 8 - Subsection 8(10) employee can sign the T2200 form where authorized to sign on employer’ s behalf
2001-07-06 28 June 2001 External T.I. 2000-0060465 F - déductibilité - frais d'internet Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(bb) internet costs incurred for investment research purposes were not deductible under s. 20(1)(bb)
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Know-How and Training internet costs incurred for investment research purposes were capital expenditures
2001-06-22 7 June 2001 External T.I. 2001-0079505 F - Gel suivi d'un rachat des actions priv. Income Tax Act - Section 248 - Subsection 248(10) issuance of preferred shares on freeze, and their redemption 3 years later, would be part of the same series
Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) safe income of common shares converted to pref under s. 51 was transferred to the pref/ non-cumulative pref dividends do not reduce safe income until declared