We have translated 6 more CRA interpretations

We have translated a further 6 CRA interpretations released in June of 2001. Their descriptors and links appear below.

These are additions to our set of 2,978 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
2001-06-22 19 June 2001 Internal T.I. 2000-0053887 F - STATUTE-BARRED YEARS - GST CREDIT Income Tax Act - Section 122.5 - Subsection 122.5(3) a taxpayer’s non-capital loss claimed for a statute-barred year eliminated his GSTC for that year, without repayment thereof being required
Income Tax Act - Section 152 - Subsection 152(4) where a taxpayer claims a non-capital loss for a statute-barred year so that his GSTC is eliminated, CCRA cannot recover the overpaid GSTC
14 June 2001 External T.I. 2000-0060085 F - Transfert à une société Income Tax Act - Section 74.4 - Subsection 74.4(2) Holdco with one discretionary share in Opco (an SBC) and which received periodic purification dividends form Opco likely would not be an SBC
12 June 2001 External T.I. 2001-0072345 F - Émigrant du Canada et statut de résident Income Tax Act - Section 2 - Subsection 2(1) cessation of Canadian residency status not significantly affected by leaving adult children behind to pursue Canadian studies (who generally would continue as residents)
2001-06-08 4 June 2001 External T.I. 2000-0047145 F - Revenu protégé - crédit impôt investis Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) investment tax credit does not reduce safe income
5 June 2001 External T.I. 2000-0055765 F - Revenu gagné en main Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) s. 85(1) exchange of common shares for preferred shares transferred the safe income on hand to the pref
Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation purification transaction accords with object and spirit of Act
1 June 2001 External T.I. 2001-0075455 F - Remaniement et capital versé Income Tax Act - Section 86 - Subsection 86(2.1) PUC reduction under s. 86(2.1) of new shares to PUC of old shares
Income Tax Act - Section 84 - Subsection 84(5) no s. 84(3) deemed dividend on s. 86 reorg by virtue of ss. 86(2.1) and 84(5)