Six further full-text translations of Technical Interpretations are available

10 May 2017 - 12:00am
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Full-text translations of the six French technical interpretations that were released between April 1, 2015 and March 11, 2015 are listed and briefly described in the table below.

These (and the other translations covering the last 26 months of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2015-04-01 9 March 2015 External T.I. 2012-0469761E5 F - Rights or things Income Tax Act - Section 70 - Subsection 70(2) right to a trust distribution to be paid out of a dividend declared but not paid by a trust investment
2015-03-25 20 January 2015 Internal T.I. 2014-0551121I7 F - Interest deductibility Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) deductible interest incurred before amalgamation not paid until thereafter
2015-03-18 19 January 2015 External T.I. 2014-0547271E5 F - SERP and Lump-Sum Averaging Income Tax Act - 101-110 - Section 110.2 - Qualifying Amount generally available for lump sum commutation from funded or unfunded SERP/T1198 recommended
Income Tax Act - Section 248 - Subsection 248(1) - Superannuation or Pension Benefit lump sum payment from funded or unfunded SERP is included
2015-03-11 14 November 2014 External T.I. 2014-0540411E5 F - Crédit d'impôt pour études Income Tax Act - Section 118.6 - Subsection 118.6(2) T2202A obligatory for student but not the school
Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program program with essentially no admission criteria was not at the post-secondary level
11 February 2015 External T.I. 2014-0557251E5 F - paragraph 110.1(1)c) and clause 55(3)(a)(i)(B) Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) "proceeds" of a gift for s. 55(3)(a)(i)(B) purposes were its deemed s. 69 proceeds of disposition
25 February 2015 External T.I. 2014-0534681E5 F - Interaction of subsections 69(11) and 70(9.01) Income Tax Act - Section 70 - Subsection 70(9.01) s. 69(11) is ousted by s. 70(9.01)