We have translated 6 more CRA interpretations
21 October 2024 - 11:32pm
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) |