We have translated 8 more CRA severed letters
14 April 2025 - 11:35pm
Email this ContentWe have translated a CRA interpretation and ruling released last week and a further 6 CRA interpretations released in October and September of 2000. Their descriptors and links appear below.
These are additions to our set of 3,167 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 |
|---|---|---|---|
| 2025-04-09 | 2024 Ruling 2023-0998291R3 F - Multi-wings split-up net asset butterfly 55(3)(b) | Income Tax Act - Section 55 - Subsection 55(1) - Distribution | split-up butterfly between a divorced couple where excess debt is allocated to land rather than building to produce capital gains treatment |
| Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(b) | excess debt allocated on s. 85(1) transfer of land and building to the land so as to produce capital gains rather than recapture | ||
| 17 January 2025 Internal T.I. 2024-1029791I7 F - SSUC - Rémunération de la haute direction / CEWS - | Income Tax Act - Section 125.7 - Subsection 125.7(1) - Executive Remuneration | no adjustments are made to an eligible entity's Statement of Executive Compensation for NEOs filed pursuant to NI 51-102 for CEWS repayment purposes | |
| Income Tax Act - Section 125.7 - Subsection 125.7(14) | repayment based on NI 51-102 statements, without adjustments | ||
| 2000-10-13 | 18 September 2000 External T.I. 2000-0026805 F - PAIEMENTS DANS LE CADRE D'UN CONGEDIEMENT | Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | payment in lieu of reasonable notice was s. 5 employment income |
| Income Tax Regulations - Regulation 102 - Subsection 102(1) | reimbursed legal costs of dismissed employee paid by the employer are not subject to withholding if such costs were deductible under s. 8(1)(b) | ||
| 3 October 2000 Internal T.I. 2000-0039997 F - VENDEAU-CONFERENCE ET CONGRES | Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) - Subparagraph 8(1)(f)(v) | costs of presentations to improve skills of salespeople who generated commissions to the taxpayer were not capital expenditures, cf. cost of attending conference | |
| 20 September 2000 External T.I. 2000-0043435 F - Associé quittant société de personnes | Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(i) | adjustments to avoid double taxation on a completed withdrawal from a partnership are considered first by the TSO, generally as part of an audit | |
| 2000-09-29 | 14 September 2000 External T.I. 2000-0037085 F - ALLOCATION DE RETRAITE | Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | a lump sum amount paid in satisfaction of salary insurance benefits could not be transmuted into a retiring allowance |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) | a lump sum paid in satisfaction of an insurer's obligations under a wage loss replacement plan were taxable irrespective of whether paid as a lump sum and via the employer | ||
| Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | lump sum wage loss payments paid by an insurance company to the employer for on-payment were subject to source deductions | ||
| 14 September 2000 External T.I. 2000-0023515 F - TAXE DE VENTE AVANTAGE IMPOSABLE | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) | payment by employer of sales tax on insurance premiums under an employee-funded sickness or accident insurance plan did not taint the plan | |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | payment by employer of sales tax on insurance premiums under an employee-funded sickness or accident insurance plan is a taxable benefit | ||
| 2000-09-15 | 11 September 2000 External T.I. 2000-0045115 F - FERR TRANSFERT | Income Tax Act - Section 60 - Paragraph 60(l) | an individual's spouse may make a transfer from a spousal RRIF a non-spousal RRIF of the spouse (which then becomes a spousal RRIF) |
| Income Tax Act - Section 146.3 - Subsection 146.3(5.1) | spousal RRIF status has relevance only for purposes of s. 146.3(5.1) |