We have translated 6 more CRA interpretations

8 October 2024 - 11:21pm
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We have translated a ruling letter and supplemental ruling letter released last week and a further 6 CRA interpretations released in July of 2001. Their descriptors and links appear below.

These are additions to our set of 2,966 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
2024-10-02 2023 Ruling 2022-0957491R3 F - Butterfly Reorganization Income Tax Act - Section 55 - Subsection 55(1) - Distribution butterfly to 2 new Holdcos of the 2 children beneficiaries of estate following the implementation by the estate of a pipeline transaction
2023 Ruling 2023-0998411R3 F - Butterfly Reorganization Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b) occurrence of 1st year ends of butterfly transferee corporations due to implementation delay caused a Pt. IV tax circularity issue
2001-07-06 7 June 2001 External T.I. 2001-0086165 F - REGLES DE ROULEMENT ET REER Income Tax Act - Section 248 - Subsection 248(1) - Taxpayer RRSP is a taxpayer
Income Tax Act - Section 85 - Subsection 85(1) ss. 85, 85.1, 86 and 87 apply to RRSPs and RRIFs
Income Tax Act - Section 87 - Subsection 87(4) s. 87(4) applies to RRSPs
14 June 2001 External T.I. 2001-0080085 F - Intérêt payé pour honorer une caution Income Tax Act - Section 20.1 - Subsection 20.1(1) s. 20.1(1) inapplicable where money borrowed to honour guarantee for wholly-owned insolvent corporation
14 June 2001 External T.I. 2001-0081885 F - Congé à traitement différé Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(a)(i) a sabbatical leave, following a deferral period, can be taken before the date initially scheduled
20 June 2001 External T.I. 2001-0086505 F - RPEB - MONTANTS PERDUS Income Tax Act - Section 144 - Subsection 144(9) s.144(9) inapplicable until employee ceases to be a beneficiary
Income Tax Act - Section 144 - Subsection 144(1) - Employee Profit Sharing Plan payment to the employer of amounts forfeited by the employee could deny EPSP status
14 June 2001 External T.I. 2000-0044935 F - Coût des actions Income Tax Act - Section 54 - Adjusted Cost Base cost to Pubco of CCPC shares acquired by it in exchange for treasury shares equal to the addition to its stated capital account, rather than the Pubco shares’ FMV
5 June 2001 External T.I. 2001-0067675 F - TRANSFERT D'ALLOCATIONS DE RETRAITE Income Tax Act - Section 60 - Paragraph 60(j.1) - Subparagraph 60(j.1)(v) years of service with former employer taken into account even if recognized solely for the purpose of limiting the reduction in the retirement benefit for early retirement