We have translated 7 more CRA severed letters

11 November 2024 - 11:21pm
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We have translated a ruling released by CRA last week and a further 6 CRA interpretations released in May of 2001. Their descriptors and links appear below.

These are additions to our set of 2,999 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 ½ 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
2024-11-06 2022 Ruling 2022-0929431R3 F - Entity classification Income Tax Act - Section 248 - Subsection 248(1) - Corporation a French société civile de placement immobilier (SCPI) is a corporation
Income Tax Act - Section 96 French SCPI is a corporation rather than partnership
2001-05-25 16 May 2001 External T.I. 2000-0053585 F - IGS SOCIETE DE PERSONNES Income Tax Act - Section 181.2 - Subsection 181.2(1) corporation would calculate its capital re a partnership that was a securities trader under s. 181.2 rather than s. 181.3
10 May 2001 External T.I. 2001-0065705 F - DEDUCTION Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) interest deductible to the extent of preferred shares dividends received, but not deductible at all for bonds acquired at a negative spread
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) s. 12(1)(c) requires the full inclusion of interest on bond acquired at a higher rate of interest, without an interest deduction
14 May 2001 Internal T.I. 2001-0065717 F - PAIEMENT INCITATIF REVENUE DE LOCATION Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Current expense vs. capital acquisition capital expenditures made by the landlord as tenant inducements are not deductible as capital expenditures
15 May 2001 External T.I. 2001-0071085 F - FABRICATION AU CANADA Income Tax Regulations - Regulation 5202 - Qualified Activities product development, design and conception work was part of the manufacturing of those products, but such manufacturing took place outside Canada
16 May 2001 External T.I. 2001-0080495 F - OPTION D'ACHAT D'ACTIONS Income Tax Act - Section 7 - Subsection 7(1.1) CCPC status tested at time of stock option agreement
16 May 2001 External T.I. 2000-0053145 F - BIEN ETRANGER MEME JOUR VENTE/ACHAT Income Tax Act - Section 54 - Adjusted Cost Base no technical limitation on increasing ACB in investments through selling and buying on same day