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

23 August 2017 - 12:09am
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Full-text translations of the final three items from the October 10. 2014 APFF Roundtable, and of three technical interpretation released on November 19, 2014, are listed and briefly described in the table below.

These (and the other translations covering the last 33 months of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2014-11-26 10 October 2014 APFF Roundtable Q. 20, 2014-0534671C6 F - D&D Livestock Income Tax Act - Section 245 - Subsection 245(4) unjustified duplication of fiscal attributes is abusive
Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(b) - Subparagraph 55(2.1)(b)(i) CRA is concerned by planining that can result in an unjustified duplication of fiscal attributes including ACB
2014-11-19 30 June 2014 Internal T.I. 2013-0508411I7 F - Part IV Tax and the Dividend Refund Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) failure to circularly calculate Part IV tax and dividend refund is neglect given published TIs
Income Tax Act - Section 186 - Subsection 186(1) when to stop circular calculation for cross dividends arising after tuck under
6 October 2014 External T.I. 2014-0543751E5 F - Rollover of a part of an interest in a partnership Income Tax Act - Section 85 - Subsection 85(1.1) fractional partnership interest qualifies as eligible property
Income Tax Act - Section 248 - Subsection 248(1) - Property partnership interest is one property - but fraction thereof also is property if transferred
17 October 2014 Internal T.I. 2014-0535121I7 F - Hypothèque et créance irrécouvrable Income Tax Act - Section 50 - Subsection 50(1) second mortgagee not entitled to deduction as it did not exercise its remedies
10 October 2014 APFF Roundtable, 2014-0538141C6 F - Interest deductibility Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest on mortgage assumed on devise of land to beneficiary considered as amount payable for the property
10 October 2014 APFF Roundtable, 2014-0538021C6 F - Meaning of beneficiary Income Tax Act - Section 248 - Subsection 248(25) Propep applied: beneficiary under s. 55(5)(e)(ii) included beneficially interested per s. 248(25)(a)
Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(e) - Subparagraph 55(5)(e)(ii) beneficiary under s. 55(5)(e)(ii) includes beneficially interested under s. 248(25)(a)