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

18 December 2017 - 10:56pm
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The table below provides descriptors and links for six French technical interpretations released in April and March of 2014, as fully translated by us.

These (and the other full-text translations covering the last 3 2/3 years of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2014-04-02 14 February 2014 External T.I. 2013-0504601E5 F - Bénéfices de fabrication et de transformation Income Tax Act - Section 125.1 - Subsection 125.1(3) - manufacturing or processing - (c) construction exclusion avoided if road asphalt is produced by related corp
General Concepts - Separate Existence avoidance through M&P carried on through related corp
24 February 2014 External T.I. 2013-0505391E5 F - Clause de earnout renversé Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) no capital gains reserve on reverse earn-out for a share sale
Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(iii) a sale price that is subject to a reverse earnout is not considered to be payable after the year (no reserve)
11 February 2014 External T.I. 2014-0517611E5 F - Actions d'une société agricole familiale Income Tax Act - Section 70 - Subsection 70(10) - Share of the Capital Stock of a Family Farm or Fishing Corporation - Paragraph (b) "principally" refers to the majority of years, so that active farming by deceased father could qualify shares, transferred years' thereafter, by passive child
7 March 2014 Internal T.I. 2013-0507171I7 F - Obligation de produire un T4A Income Tax Regulations - Regulation 200 - Subsection 200(1) dual T4A issuance for fees to artist's corporation and dues to the artist's union
7 March 2014 Internal T.I. 2013-0506671I7 F - Subparagraph 104(27)(d)(ii) and paragraph 60(j) Income Tax Act - 101-110 - Section 104 - Subsection 104(27) - Paragraph 104(27)(d) - Subparagraph 104(27)(d)(ii) flow-through pension benefit must have been an s. 60(j) eligible amount had it had been received directly
2014-03-26 20 February 2014 External T.I. 2013-0480051E5 F - Eligible dividend and safe income Income Tax Act - Section 89 - Subsection 89(1) - General Rate Income Pool full amount of designated dividend reduces payor's GRIP even though recipient's GRIP increased only by safe income portion
Income Tax Act - Section 89 - Subsection 89(14) eligible dividend designation treated as applying only to safe income portion of dividend