We have translated 6 more CRA interpretations

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

These are additions to our set of 3,017 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
2001-04-27 10 April 2001 External T.I. 2001-0078035 F - RAP PERSONNE DIVROCEE Income Tax Act - Section 146.01 - Subsection 146.01(1) - Regular Eligible Amount - Paragraph (f) divorced individual was eligible notwithstanding ownership during their marriage of home by ex-spouse
12 April 2001 External T.I. 2000-0050655 F - ASSURANCE MUTILATION/INVALIDITE Income Tax Act - Section 148 - Subsection 148(9) - Disposition - Paragraph (h) disability benefits under a policy providing life and accidental death and dismemberment insurance could be non-taxable
Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account personal injury amounts received pursuant to life insurance policy not added to CDA
23 March 2001 Internal T.I. 2000-0056097 F - Roulement interne Income Tax Act - Section 84 - Subsection 84(1) s. 84(1) deemed dividend where individual’s low-PUC common shares are exchanged with the corporation for high-PUC preferred shares and there is an s. 85(1) agreed amount at FMV
17 April 2001 External T.I. 2000-0056455 F - AVANTAGE IMPOSABLE-EMPLOYE Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) the distribution of employer shares to employees as beneficiaries of a discretionary trust is a s. 6(1)(a) benefit if it has the slightest connection to their employment
2 February 2001 Internal T.I. 2000-0058127 F - Convention d'émission d'actions
follow-up in 2001-007939 F

Income Tax Act - Section 7 - Subsection 7(2) s. 7(2) could apply if shares were held by the employer for later acquisition by the employee
19 April 2001 Internal T.I. 2001-0069067 F - PENSION ALIMENTAIRE ACCORD ECRIT Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount submitted documents were not a written agreement