We have translated 7 more CRA interpretations
9 December 2024 - 11:15pm
Email this ContentWe have translated a CRA interpretation released by CRA last week and a further 6 CRA interpretations released in April of 2001. Their descriptors and links appear below.
These are additions to our set of 3,024 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 ¾ 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 |
|---|---|---|---|
| 2024-12-04 | 19 January 2024 External T.I. 2020-0865921E5 F - Foreign Currency dispositions by an individual | Income Tax Act - Section 39 - Subsection 39(1.1) | foreign currency dispositions under s. 39(1.1) include FX bank deposit conversions |
| 2001-04-13 | 28 March 2001 External T.I. 2001-0070415 F - Interaction entre les articles 51 et 116 | Income Tax Act - Section 116 - Subsection 116(5) | acquisition of the exchanged shares by the corporation on a s. 51 exchange at a cost equal to PUC of issued shares |
| Income Tax Act - Section 54 - Adjusted Cost Base | a corporation acquires shares in its capital on a s. 51 exchange at a cost equal to the PUC of the shares issued therefor | ||
| Income Tax Act - Section 116 - Subsection 116(6) - Paragraph 116(6)(a) | s. 116(6)(a) does not apply to shares acquired by Canco on a s. 51 exchange of Canco shares | ||
| Income Tax Act - Section 51 - Subsection 51(1) | on a s. 51 exchange, the corporation is considered to have acquired the exchanged shares at a cost equal to the PUC of the shares issued by it | ||
| 26 March 2001 External T.I. 2001-0070165 F - Conventions fiscales et lois provinciales | Treaties - Income Tax Conventions - Article 12 | Canada will not reduce its withholding rate to 0% to make room for Quebec taxes imposed on the same property income | |
| Treaties - Income Tax Conventions - Article 2 | Canada has no obligation to absorb Quebec taxes imposed on property income with treaty-reduced withholding | ||
| 26 March 2001 External T.I. 2001-0070585 F - Interaction entre Convention Canada-US et LIR | Treaties - Income Tax Conventions - Article 13 | Art. XIII(5) of Canada-US treaty applies to disposition of Amalco shares that were exchanged on the amalgamation for shares subjected to a deemed disposition under s. 128.1(4)(b) | |
| 29 March 2001 External T.I. 2001-0071825 F - Application de 132(6) et 132(6.1) | Income Tax Act - Section 132 - Subsection 132(6.1) | if trust did not have 150 beneficiaries by the 90th-day deadline, it can only qualify prospectively as a MFT after satisfying the conditions | |
| 5 April 2001 External T.I. 2000-0058445 F - Entreprise de gestion et REATB | Income Tax Act - Section 95 - Subsection 95(1) - Investment Business | a management services business was not an investment business | |
| Income Tax Act - Section 95 - Subsection 95(2) - Paragraph 95(2)(b) | s. 95(2)(b) application to provision of services to rental partnerships | ||
| 29 March 2001 External T.I. 2001-0064585 F - Application de 13(21.2)e)(iii)(C) | Income Tax Act - Section 13 - Subsection 13(21.2) - Paragraph 13(21.2)(e) - Subparagraph 13(21.2)(e)(iii) - Clause 13(21.2)(e)(iii)(C) | s. 13(21.2)(e)(iii)(C) is not engaged when the affiliated transferee becomes a non-resident |