We have translated 6 more CRA interpretations
24 December 2024 - 1:52pm
Email this ContentWe have translated a further 6 CRA interpretations released in March of 2001. Their descriptors and links appear below.
These are additions to our set of 3,047 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 |
|---|---|---|---|
| 2001-03-30 | 9 January 2001 Internal T.I. 2000-0058047 F - FRAIS JURIDIQUES | Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | debt of corporation to a director arising from his discharge of joint and several liability for unpaid taxes was not a debt acquired for income-producing purpose |
| Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | director’s legal fees incurred re his liability for unpaid corporate GST were non-deductible | ||
| 2 March 2001 External T.I. 2001-0069555 F - Dividendes - (U.S. spin-off) | Income Tax Regulations - Regulation 201 - Subsection 201(2) | T5 reporting obligation of broker also applies to s. 86.1 spin-off | |
| Income Tax Act - Section 86.1 - Subsection 86.1(2) | detailed review of proposed s. 86.1 | ||
| 19 March 2001 External T.I. 2001-0063345 F - RS & DE - MANDATAIRE | Income Tax Act - Section 37 - Subsection 37(1) - Paragraph 37(1)(a) - Subparagraph 37(1)(a)(ii) - Clause 37(1)(a)(ii)(E) | organization did not qualify under s. 37(1)(a)(ii)(E) because it made disbursements only as agent | |
| 23 February 2001 External T.I. 2001-0066265 F - Salaire différé français | Income Tax Act - Section 3 - Paragraph 3(a) | receipt of “deferred salary,” pursuant to a right established by French legislation, as compensation for contribution to the family farm was not income | |
| Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (b) - Subparagraph (b)(ii) | receipt of “deferred salary,” pursuant to a right established by French legislation, was not a pension given no previous employer-employee relationship | ||
| Income Tax Act - Section 248 - Subsection 248(1) - Property | “deferred salary” right of farmer descendant was a debt | ||
| Treaties - Income Tax Conventions - Article 18 | receipt of “deferred salary,” pursuant to a right established by French legislation, was not a pension given no previous employer-employee relationship | ||
| 11 January 2001 Internal T.I. 2000-0037167 F - CLAUSE D'AJUSTEMENT DE PRIX | Income Tax Act - Section 54 - Adjusted Cost Base | post-closing indemnity payments received by purchaser reduced the ACB of its purchased shares | |
| Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | damages received by share purchaser reduced the ACB of its shares and were not a taxable capital gain | ||
| 8 March 2001 External T.I. 2000-0048405 F - Usufruit sur immeuble en France | Income Tax Act - Section 248 - Subsection 248(3) | s. 248(3) and 75(2) subject bare owner to tax on rental income under Quebec usufruct/ the converse if a French usufruct |