Six further full-text translations of CRA technical interpretations are available

7 June 2017 - 12:16am
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Full-text translations of the six French technical interpretations that were released last week and between February 4, 2015 and January 28, 2015, are listed and briefly described in the table below.

These (and the other translations covering the last 28 months of CRA releases) are subject to the usual (3 working weeks per month) paywall. You are currently in the “open” week for June.

Bundle Date Translated severed letter Summaries under Summary descriptor
2017-05-31 30 March 2017 External T.I. 2015-0609951E5 F - Article 18 of the Canada-Turkey Income Tax Convention Other Legislation/Constitution - Federal - Income Tax Conventions Interpretation Act - Section 5 - Pension RRSP annuity payments to Turkish resident were subject to Pt XIII tax as pension payments
Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(d) capital components are not deduction of cost
Treaties - Article 18 capital portion of s. 56(1)(d) is not excluded as an annuity under Canada-Turkey Treaty/RRSP annuity payments are pensions
2015-02-04 19 January 2015 External T.I. 2013-0511381E5 F - Disposition subject to warranty Income Tax Act - Section 42 loss not claimable by estate
17 October 2014 Internal T.I. 2014-0546091I7 F - Indemnités lors d'une négociation de gré à gré Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) indemnity payment received re principal residence could be exempted under s. 40(2)(b)
8 December 2014 External T.I. 2014-0543891E5 F - Régime privé d'assurance-maladie Income Tax Act - Section 248 - Subsection 248(1) - Private Health Services Plan CRA willing to treat a flex plan as being bifurcated into a PHSP and non-PHSP if medical expense portion is recorded separately
2015-01-28 10 November 2014 External T.I. 2014-0536851E5 F - Terre à bois et Plan d'aménagement forestier Income Tax Act - Section 73 - Subsection 73(3) - Paragraph 73(3)(c) mere absence of a FMP does not preclude the rollover
17 October 2014 Internal T.I. 2014-0535561I7 F - Application du paragraphe 249(3) Income Tax Act - Section 249 - Subsection 249(3) subsequent stub period income is excluded