Seven further full-text translations of CRA technical interpretations/Roundtable items are available

15 August 2017 - 11:58pm
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Full-text translations of a further three items from the October 10. 2014 APFF Roundtable, and of three technical interpretation released on December 3, 2014, are listed and briefly described in the table below. In addition, last week CRA released a technical interpretation (2017-0683511E5 F, respecting the use of s. 55(3)(a) to distribute cash otherwise than from safe income likely being abusive) which we published in French and translated form several months ago.

These (and the other translations covering the last 32 months of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2014-12-10 10 October 2014 October APFF Roundtable Q. 18, 2014-0538081C6 F - 2014 APFF Roundtable, Q. 18 - Connected corporations Income Tax Act - Section 186 - Subsection 186(2) test contemplates relative number of voting shares
2014-12-03 15 October 2014 External T.I. 2014-0547551E5 F - Acquisition of Control Income Tax Act - Section 249 - Subsection 249(4) reduction in CCPC shareholders from 7 to 4 likely would result in AOC
Income Tax Act - Section 251.2 - Subsection 251.2(2) - Paragraph 251.2(2)(a) shrinking of CCPC control group likely was AOC if sufficiently material
2 October 2014 External T.I. 2013-0513281E5 F - Interaction entre 42(1) et 39(1)c) Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) s. 42(1)(b)(ii) payments currently do not qualify as BILs
Income Tax Act - Section 42 no deeming of s. 42(1)(b)(ii) loss to arise from the SBC shares, so that not a BIL
6 November 2014 External T.I. 2014-0528521E5 F - Payment of management fees by employer Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) taxable benefit on employer payment of RRSP (including LIRA) and TFSA fund management fees but not those of DPSPs or SERPs
Income Tax Act - Section 146 - Subsection 146(1) - Retirement Savings Plan LIRA treated as RRSP
2014-11-26 10 October 2014 APFF Roundtable, 2014-0534811C6 F - Interest deductibility Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) no deductibility if permanent policy of not paying dividends
10 October 2014 APFF Roundtable, 2014-0534841C6 F - Majority-interest beneficiary Income Tax Act - Section 251.1 - Subsection 251.1(3) - Majority-interest beneficiary includes affiliates with no actual beneficial interest in trust