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

29 November 2017 - 1:36am
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The table below provides descriptors and links for five French technical interpretation released in April 2014, as fully translated by us.

These (and the other full-text translations covering the last 3 ½ years of CRA releases) are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for December.

Bundle Date Translated severed letter Summaries under Summary descriptor
2014-04-30 10 March 2014 Internal T.I. 2013-0493971I7 F - Application of section 120.4 Income Tax Act - 101-110 - Section 103 - Subsection 103(1.1) allocation of income to partner not responsible for expenses
Income Tax Act - 101-110 - Section 103 - Subsection 103(1) income-splitting partnership terms
Income Tax Act - Section 120.4 - Subsection 120.4(1) - split income - (c) LP income not from property provision or services
27 March 2014 External T.I. 2014-0520941E5 F - Industrial mineral mine and related expenditures Income Tax Act - Section 13 - Subsection 13(7.5) - Paragraph 13(7.5)(b) access road deemed to have been "acquired"
Income Tax Regulations - Schedules - Schedule II - Class 17 access road to quarry was Class 17 property notwithstanding that not owned
Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(g) ordinary meaning of "mineral"
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Start-Up and Close-Down Expenditures expenditures deductible where incurred prior to acquisition decision
26 March 2013 External T.I. 2014-0523251E5 F - Acquisition of control and amalgamation Income Tax Act - Section 249 - Subsection 249(4) double taxation year ends where transactions occur on the closing date before acquisition and amalgamation
Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) double taxation year ends where transactions occur on the closing date before acquisition and amalgamation
2014-04-23 9 April 2014 External T.I. 2013-0503421E5 F - Transitional reserve Income Tax Act - Section 34.2 - Subsection 34.2(11) transitional adjustment where partnership loss in year 1 followed by 2 profitable years
31 January 2014 External T.I. 2013-0500501E5 F - Indien - Retenues à la source - RPA Other Legislation/Constitution - Federal - Indian Act - Section 87 procedure for adjusting exempt portion of prior years’ RPP pension payments made to Indian