We have translated 6 more CRA interpretations
10 March 2025 - 10:11pm
Email this ContentWe have translated a further 6 CRA interpretations released in December of 2000. Their descriptors and links appear below.
These are additions to our set of 3,129 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 ¼ 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 |
|---|---|---|---|
| 2000-12-22 | 21 September 2000 Internal T.I. 2000-0046180 F - Remboursement de dépenses | Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv) | settlement agreement compensation for mortgage (including principal) payments that B had paid on a mortgage that A assumed as of an earlier partition date, was s. 12(1)(x)(iv) income to B |
| 25 October 2000 Internal T.I. 2000-0044547 F - REGIME DE PRESTATIONS AUX EMPLOYES | Income Tax Act - Section 248 - Subsection 248(1) - Employee Benefit Plan | job security fund was an EBP | |
| 2000-12-08 | 4 December 2000 External T.I. 2000-0001715 F - Qualified small business corporation share | Income Tax Act - Section 48.1 - Subsection 48.1(1) | s. 48.1 election could be made respecting the accrued capital gain on shares that ceased to be QSBCS on a narrowing of the CCPC definition re a connected corp. |
| Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation - Paragraph (c) | para. (c) relevant where Holdco’s asset was shares of Opco but Opco shares also were held by Pubco | ||
| 30 November 2000 External T.I. 2000-0026615 F - GAAR | Income Tax Act - Section 83 - Subsection 83(2) | streaming of CDA to particular shareholders is not abusive if s. 83(2.1) is complied with | |
| Income Tax Act - Section 83 - Subsection 83(2.1) | CDA streaming generally does not violate s. 83(2.1) or GAAR where the objective is to pay capital dividends to taxpayers who were already shareholders | ||
| Income Tax Act - Section 245 - Subsection 245(4) | CDA streaming between existing shareholders is generally acceptable | ||
| 5 December 2000 External T.I. 2000-0047515 F - Impôts financiers intérêts terrain vacant | Income Tax Act - Section 10 - Subsection 10(1) | interest and property taxes may be added to the cost of real estate inventory on general principles | |
| 5 December 2000 External T.I. 2000-0055815 F - Grief réglé après décès | Income Tax Act - Section 5 - Subsection 5(1) | retroactive salary adjustment that was not determined by tribunal until after employee’s death not taxable to him or estate (although heirs were taxable on interest component) | |
| Income Tax Act - Section 70 - Subsection 70(2) | retroactive salary adjustment that was not determined by tribunal until after employee’s death was not a right or thing at death |