We have translated 7 more CRA interpretations
3 February 2025 - 11:26pm
Email this ContentWe have translated a CRA interpretation released last week and a further 6 CRA interpretations released in February of 2001. Their descriptors and links appear below.
These are additions to our set of 3,097 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 24 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 |
|---|---|---|---|
| 2025-01-29 | 28 November 2024 External T.I. 2024-1026331E5 F - Section 87 of the Indian Act | Other Legislation/Constitution - Federal - Indian Act - Section 87 | reserve residents generally can exempt their employment earnings by agreeing to perform over half of their duties from home |
| 2001-02-02 | 16 January 2001 External T.I. 2000-0009685 F - avantage - usage par l'actionnaire | Income Tax Act - Section 15 - Subsection 15(1) | no s. 15(1) benefit where aircraft of corporation is used for the personal benefit of its sole shareholder, who bears the cost and expenses |
| 25 January 2001 External T.I. 2000-0049565 F - PAIEMENTS FORFAITAIRES RETROACTIFS | Income Tax Act - 101-110 - Section 110.2 - Subsection 110.2(1) - Qualifying Amount | retiring allowance could qualify if paid pursuant to settlement agreement of an action, and could be specified portion if related to prior year’s lost income | |
| 22 January 2001 External T.I. 2000-0012025 F - cotisations sociales | Income Tax Act - Section 126 - Subsection 126(7) - Non-Business-Income Tax | Belgian social security contributions imposed on Belgian director’s fees (treated as self-employed earnings for Belgian purposes) were non-business-income taxes | |
| 24 January 2001 External T.I. 2000-0028895 F - Contingent de versement/perte | Income Tax Act - Section 149.1 - Subsection 149.1(1) - Disbursement Quota | investment of amount or depreciation in the investment is not the expending of an amount | |
| 17 January 2001 External T.I. 2000-0041375 F - REMBOURSEMENT DE PRIME/ENFANT INFIRME | Income Tax Act - Section 146 - Subsection 146(8.1) | s. 146(8.1) election and s. 60(l)(ii) transfer re bequest of RRSP to adult disabled child’s RRSP | |
| 23 January 2001 External T.I. 2000-0045445 F - DETTE D'UN ACTIONNAIRE - FIDUCIE | Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(b) | where Opco makes a loan to a wholly-owned trust, the shareholder of Opco does not deal at arm’s length with the trust | |
| Income Tax Act - Section 15 - Subsection 15(2) | where Opco makes a loan to a wholly-owned trust, the loan is included in the trust’s income assuming that an Opco shareholder did not deal with it at arm’s length with Opco |