We have translated over 3,000 severed letters
18 November 2024 - 11:20pm
Email this ContentWe have translated a further 6 CRA interpretations released in May of 2001. Their descriptors and links appear below.
These are additions to our set of 3,005 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 |
|---|---|---|---|
| 2001-05-25 | 10 May 2001 Internal T.I. 2001-0066107 F - TABLE RONDE - QUESTION 32 | Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | absence of cost step-up to s. 69(1)(b) transferee does not produce a capital gain on subsequent disposition due to such gain being recapture pursuant to s. 13(7)(e)(iii) |
| Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) | parenthetical exclusion prevents double taxation to a NAL transferee otherwise arising from the deemed high capital cost under s. 13(7)(e)(iii) but with no ACB step-up under s. 69(1)(b) | ||
| 10 May 2001 Internal T.I. 2001-0065727 F - AVANTAGE - FONCTIONNEMENT AUTOMOBILE | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(l) | s. 6(1)(l) can include a benefit relating to the operation of an automobile in the income of an employee of a member of a partnership | |
| Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(y) | unlike standby benefit, operating benefit for an employee of a partnership member is addressed by s. 6(1)(l) | ||
| 10 May 2001 Internal T.I. 2001-0066047 F - CRITERES RÉSIDENCES D'ACCUEIL | Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(h) | taxpayer must ordinarily reside at the place as a principal residence | |
| 10 May 2001 Internal T.I. 2001-0066067 F - SOCIÉTÉ DE PERSONNES - PARTAGE REVENU | Income Tax Act - Section 53 - Subsection 53(2) - Paragraph 53(2)(c) - Subparagraph 53(2)(c)(v) | salary paid to partners is treated as drawings and is an ACB deduction rather than an income deduction | |
| Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | partner salaries are non-deductible | ||
| 14 May 2001 Internal T.I. 2001-0065687 F - VENTE CREANCE A ESCOMPTE | Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (b) - Subparagraph (b)(i) | blended monthly payments of interest and principal received pursuant to a mortgage acquired at a discount each gave rise to a capital gain | |
| Income Tax Act - Section 43 - Subsection 43(1) | apportioned ACB of discounted mortgage that is disposed of with each blended payment is determined by apportioning the discount | ||
| Income Tax Act - Section 9 - Computation of Profit | holder on income account of a mortgage can choose to recognize the discount only after he has recovered his purchase price through the blended principal payments | ||
| Income Tax Act - Section 20 - Subsection 20(14) | application of s. 20(14) to acquisition of mortgage | ||
| 10 May 2001 Internal T.I. 2001-0065697 F - SOCIÉTÉ EXERCANT UNE PROFESSION LIBERALE | General Concepts - Illegality | where profession is carried on in a corporation contrary to the regulatory requirements, the corporate income is earned by the professional | |
| Income Tax Act - Section 9 - Nature of Income | income earned by a professional corporation contrary to the professional rules is personal income of the professional |