We have translated 6 more CRA interpretations

15 October 2024 - 11:30pm
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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 2,972 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 3 July 2001 Internal T.I. 2001-0076867 F - frais de garde-inscription Income Tax Act - Section 63 - Subsection 63(3) - Child Care Expense childcare centre annual registration fee is included
22 June 2001 Internal T.I. 2001-0078457 F - Décret remise d'impôt revenu gagné au Québec Income Tax Act - Section 248 - Subsection 248(1) - Taxable Canadian Property - Paragraph (a) gold royalty was neither TCP nor real property
29 May 2001 External T.I. 2001-0082675 F - CONGE A TRAITEMENT DIFFERE ET RETRAITE Income Tax Regulations - Regulation 6801 - Paragraph 6801(a) - Subparagraph 6801(a)(v) employee may withdraw from the plan in special circumstances stipulated in the plan such as lay-off
10 May 2001 External T.I. 2001-0066095 F - CREDIT-BAIL Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A following Shell, CCRA will only recharacterize a lease where the true legal relationship is not of a lease
Income Tax Act - Section 248 - Subsection 248(3) Construction Bérou did not comment on the CCRA’s current position on what is a lease
2001-06-22 19 June 2001 External T.I. 2000-0058665 F - CESSION DE PENSION ALIMENTAIRE Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) support payments assigned to the Ontario Ministry of Community and Social Services and paid in arrears in order to receive social assistance payments were not taxable
21 June 2001 External T.I. 2001-0086285 F - Disposition transitoire à 112(3) Income Tax Act - Section 112 - Subsection 112(3) condition in 1995 transitional provision for the financing of the redemption of a preferred share includes part of a share
Income Tax Act - Section 248 - Subsection 248(1) - Share condition re financing the redemption of a preferred share included part of a preferred share
General Concepts - Transitional Provisions and Policies transitional provision re “share” to be applied on a share-by-share basis