We have translated 6 more CRA interpretations

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

These are additions to our set of 2,958 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 ¼ 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
2001-07-06 28 June 2001 External T.I. 2001-0078935 F - waiving of dividend Income Tax Act - Section 15 - Subsection 15(1) CCRA will rule on whether s. 245(2) applies to a dividend waiver
28 June 2001 External T.I. 2000-0061365 F - Frais de déplacement - athlètes Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) travel and accommodation expenses satisfying s. 18(1)(h) must also satisfy s. 18(1)(a)
Income Tax Act - Section 3 - Paragraph 3(a) receipts under Athlete Assistance Program are non-taxable
20 June 2001 External T.I. 2001-0066825 F - REGLES D'ATTRIBUTIONS Income Tax Act - Section 74.1 - Subsection 74.1(1) ss. 74(1) and (2) applied to dividends and taxable capital property received from the spouse before May 23, 1985
26 June 2001 External T.I. 2001-0068285 F - DATE DE DISPOSITION ACTIONS EN BOURSE Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (a) disposition date on a stock exchange is the settlement date, being the due date for the proceeds
28 June 2001 External T.I. 2001-0069865 F - CRÉDIT-BAIL Income Tax Act - Section 248 - Subsection 248(3) Construction Bérou interpretation of s. 248(3) was erroneous
Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A Construction Bérou should not be followed in finding that a lessee can be the tax owner of the leased property
22 June 2001 External T.I. 2001-0075275 F - Dommages-intérêts
confirmed in 2001-0092105 F

 Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) damages pursuant to Article 1617 of the CCQ, being damages resulting from delay in the performance of an obligation to pay a legacy, were taxable as interest