Full-text translations of the French technical interpretation released last week, of a further five items from the October 10. 2014 APFF Roundtable, and of a technical interpretation released on December 17, 2014, are listed and briefly described in the table below.
These (and the other translations covering the last 32 months of CRA releases) are subject to the usual (3 working weeks per month) paywall. You are currently in the “open” week for August.
| Bundle Date |
Translated severed letter |
Summaries under |
Summary descriptor |
| 2017-08-02 |
12 July 2017 Ministerial Correspondence 2017-0697761M4 F - Publicité des plateformes Web étrangères |
Income Tax Act - Section 19.1 - Subsection 19.1(1) |
ads by Canadian advertisers on foreign websites generally are deductible |
| 2014-12-17 |
7 November 2014 External T.I. 2014-0549571E5 F - Attribution rule |
Income Tax Act - Section 74.4 - Subsection 74.4(4) |
disqualification by interests held through a 2nd corporation |
| 2014-12-10 |
10 October 2014 APFF Roundtable Q. 23, 2014-0538171C6 F - 2014 APFF Roundtable, Q. 23 - Winding-up of a partnership |
Income Tax Act - Section 98 - Subsection 98(3) |
no rollover where 2nd tier partnership acquires all partnership interests in 1st tier partnership |
| 10 October 2014 APFF Roundtable Q. 24, 2014-0538181C6 F - 2014 APFF Roundtable, Q. 24 - Surplus accounts calculation |
Income Tax Regulations - Regulation 5907 - Subsection 5907(6) |
criteria for determining whether use by FA of Cdn$ presents fair picture of surpluses |
| 10 October 2014 APFF Roundtable Q. 26, 2014-0538201C6 F - 2014 APFF Roundtable, Q. 26 - Cost of property |
General Concepts - Fair Market Value - Shares |
definition of FMV, which may differ from the s. 247 arm's length price |
| Income Tax Act - Section 247 - New - Subsection 247(2) |
arm's length transfer price prevails over FMV |
| Income Tax Act - Section 247 - New - Subsection 247(3) - Subparagraph 247(3)(a) - Subparagraph 247(3)(a)(iii) |
general requirement for penalty elimination re transfer pricing capital setoff adjustment |
| 10 October 2014 APFF Roundtable Q. 27, 2014-0538211C6 F - 2014 APFF Roundtable, Q. 27 - Various issues re: administration of the Act |
Income Tax Act - Section 162 - Subsection 162(7.1) |
no T5013/T3 late filing penalty where filing after waiving of filing requirement |
| Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(a) |
reporting of income-generating websites on Sched. 88 (info only, but not bank, sites excluded) |
| 10 October 2014 October APFF Roundtable Q. 17, 2014-0538071C6 F - 2014 APFF Roundtable, Q. 17 - Related Group |
Income Tax Act - Section 251 - Subsection 251(3) |
related corporations whose shareholders are not all related |
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