Translations of French Severed Letters now go back 18 months

21 February 2017 - 11:49pm
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Full-text translations of seven technical interpretations released in French between September 23, 2015 and August 19, 2015 are now available - and are listed and briefly described in the table below.

These (and the other translations covering the last 18 months of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2015-09-23 11 August 2015 External T.I. 2015-0592441E5 F - Test wind turbines Income Tax Regulations - Regulation 1219 - Subsection 1219(3) change to GPS coordinates does not affect 2013-0490631E5
2015-09-16 5 June 2015 Internal T.I. 2015-0569061I7 F - Non-interest-bearing loan to a controlled foreign affiliate Income Tax Act - Section 17 - Subsection 17(8.1) - Paragraph 17(8.1)(b) debt owing to CFA parent, which had funded active business assets and was assumed on absorptive merger, qualified under s. 17(8.1)(b)
25 June 2015 External T.I. 2014-0553181E5 F - Graduated rate estate Income Tax Act - Section 248 - Subsection 248(1) - Graduated Rate Estate only an estate, not a testamentary trust, can qualify
25 August 2015 External T.I. 2015-0571271E5 F - Affiliated Trusts under Paragraph 251.1(1)(h) Income Tax Act - Section 251.1 - Subsection 251.1(3) - Contributor deceased settlor of Trust B was an affiliated contributor to her brother, who contributed to Trust A
2015-09-02 18 June 2015 External T.I. 2015-0578071E5 F - Reimbursement of overpayment of QPIP benefits Income Tax Act - Section 60 - Paragraph 60(n) - Subparagraph 60(n)(v.1) no s. 60 deductions if non-resident
Income Tax Act - Section 4 - Subsection 4(2) s. 60 deduction denied for repayment of previous income inclusion
Other Legislation/Constitution - Federal - Financial Administration Act - Subsection 23(2) general criteria for granting remission
2015-08-19 23 June 2015 External T.I. 2015-0571801E5 F - Allocation of Capital Gains to Beneficiaries Income Tax Act - 101-110 - Section 104 - Subsection 104(21.2) allocation of QSBC gain to a beneficiary added after QSBC disposition
24 June 2015 External T.I. 2015-0565951E5 F - Legatee by particular Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Beneficiary legatee by particular title is a beneficiary even if not an heir
Income Tax Act - 101-110 - Section 104 - Subsection 104(13) allocation of interest income of succession to legatee by particular title