We have translated 8 more CRA interpretations

7 April 2025 - 11:22pm
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We have translated two CRA interpretations released last week and a further 6 CRA interpretations released in November and October of 2000. Their descriptors and links appear below.

These are additions to our set of 3,159 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 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
2025-04-02 19 February 2025 External T.I. 2018-0744821E5 F - Régime d’assurance collective - groupe de personne Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) for a 2-person plan, a higher level of benefits for the majority shareholder would suggest that there was an individual policy for him, rather than being a group plan component
Income Tax Act - Section 15 - Subsection 15(1) rebuttable presumption that benefits of shareholder-employees from disability plan premiums were taxable/ meaning of "contemplated" shareholder
11 March 2025 External T.I. 2020-0845931E5 F - Transfert d’une propriété intellectuelle Income Tax Act - Section 9 - Capital Gain vs. Profit - Patents and Know-How the consequences of a sale of IP by a partnership for the benefit of a university and its researchers might be addressed in a ruling
2000-11-10 25 October 2000 External T.I. 2000-0017065 F - CONVENTION DE RETRAITE ET ASSURANCE Income Tax Act - Section 207.6 - Subsection 207.6(2) no Pt. XI.3 tax to RCA trust on withdrawals from the life insurance policy funding the RCA
13 October 2000 Internal T.I. 2000-0042477 F - depenses d'emploi-vendeur valeurs mobiliers Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) - Subparagraph 8(1)(f)(ii) requirement to perform duties away from the office can be implied
18 September 2000 Internal T.I. 2000-0043647 F - Perte transfert bâtiment personne affiliée Income Tax Act - Section 13 - Subsection 13(21.2) - Paragraph 13(21.2)(b) proceeds of disposition of a building are determined first under s. 13(21.1) before applying s. 13(21.2)(b)
Income Tax Act - Section 13 - Subsection 13(21.1) s. 13(21.1) applied first before stop-loss rule in s. 13(21.2) applied
2000-10-27 19 October 2000 External T.I. 2000-0027795 F - SOCIETES PRIVEES SOUS CONTROLE CDN Income Tax Act - Section 125 - Subsection 125(3) corporations controlled by the provincial Crown, required to share their business limit
Income Tax Act - Section 181.5 - Subsection 181.5(6) corporations controlled by the provincial Crown would not be required to share their capital deduction
Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation corporations controlled by the provincial Crown treated as CCPCs
Income Tax Act - Section 248 - Subsection 248(1) - Person provincial Crown is a person
23 October 2000 External T.I. 2000-0038305 F - REMBOURSEMENT DE PRIME CONJOINT MEME SEXE Income Tax Act - Section 146 - Subsection 146(8.1) election to have the deceased by a common-law partner could be made with deceased’s executor, thereby enabling a s. 146(8.1) election
2000-10-13 2 October 2000 External T.I. 2000-0015825 F - ACTIFS AUX FINS DE LA LOI Income Tax Act - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (c) a future income tax asset (including one not recognized on the balance sheet) must be taken into account for QSBCS and SBC purposes, but is not used in the business
Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation a future income tax asset is an asset for QSBCS and SBC purposes, but is not used in the business