Translations of recent severed letters

Bundle Date Translated severed letter Summaries under Summary descriptor
2000-06-09 11 May 2000 External T.I. 2000-0009605 F - Démolition d'un immeuble Income Tax Act - Section 54 - Superficial Loss no superficial loss where demolition of building
Income Tax Act - Section 40 - Subsection 40(3.3) no suspended loss where demolition of building
15 May 2000 External T.I. 2000-0001995 F - CONGE SANS SOLDE-REGIME DISTINCT Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) payment of premiums by employee during unpaid leave did not create a separate plan, so that any benefits received would still be taxable
15 May 2000 Income Tax Severed Letter 2000-0008210 F - ADMINISTRATEUR DE FACTO Income Tax Act - Section 227.1 - Subsection 227.1(1) individual can be a de facto director who acts as such with the shareholders’ agreement or takes significant actions with 3rd parties in the corporation’s name
11 May 2000 Internal T.I. 2000-0008270 F - Perte finale disposition bâtiment Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) s. 13(21.1)(b) would apply to reduce terminal loss even if the land was disposed of at a loss in a previous year
31 May 2000 External T.I. 2000-0009695 F - FRAIS MEDICAUX-PREPOSE A PLEIN TEMPS Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(b) meaning of “one full-time attendant … for the full-time care of the individual”
5 June 2000 External T.I. 2000-0010615 F - Developpement d'un equipement - RS&DE Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(d) expenditures to develop SR&ED equipment could be current expenses
24 May 2000 Internal T.I. 2000-0017677 F - PENSION ALIMENTAIRE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount payments made pursuant to a separation agreement in order to maintain a financial balance between them rather than for maintenance, were not support amounts
8 June 2000 External T.I. 1999-0006105 F - TRANSFERT DE BIENS A UN CONJOINT Income Tax Act - Section 74.1 - Subsection 74.1(1) CCRA has not yet developed a position re where the transferred property itself is returned to the transferor spouse in repayment of the transferee spouse’s debt
17 May 2000 External T.I. 1999-0011695 F - Revenu protégé - options et dividendes Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) safe income of Pubco allocated to option granted to a minority shareholder to acquire its shares, but reduced by Pubco dividends
17 March 2000 APFF Roundtable Q. 11, 2000-0008260 F - DEDUCTION POUR PLACEMENTS Income Tax Act - Section 181.2 - Subsection 181.2(4) - Paragraph 181.2(4)(b) balance of sale, although a debt, is not a “loan or advance”/ prepaid expenses are “advances”

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