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

1 January 2018 - 11:08pm
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The table below provides descriptors and links for two French technical interpretations released last week and four technical interpretations released in March and February of 2014, as fully translated by us.

These (and the other full-text translations covering the last 3 ¾ years of CRA releases) are subject to the usual (3 working weeks per month) paywall. You are currently in the “open” week for January.

Bundle Date Translated severed letter Summaries under Summary descriptor
2017-12-27 27 October 2017 External T.I. 2017-0688971E5 F - New Class 14.1 Income Tax Act - Section 13 - Subsection 13(39) non-application on s. 85 roll can result in recapture -but disposition bump available to NAL transferee
Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(e) permitted agreed amount for Class 14.1 property rollover must be UCC even where amortized cost (equalling boot) is higher
Income Tax Act - Section 13 - Subsection 13(38) - Paragraph 13(38)(c) a s. 85 roll of purchased goodwill at an agreed amount of unamortized cost can trigger recapture
31 October 2017 External T.I. 2017-0690691E5 F - New section 15 back to back loan rules Income Tax Act - Section 15 - Subsection 15(2.16) - Paragraph 15(2.16)(c) - Subparagraph 15(2.16)(c)(i) - Clause 15(2.16)(c)(i)(B) application to a term deposit pledged by a family corporation to secure a business loan taken out by a shareholder
Income Tax Act - Section 15 - Subsection 15(2.16) - Paragraph 15(2.16)(c) - Subparagraph 15(2.16)(c)(ii) term deposit to secure shareholder loan potentially a specifed right
Income Tax Act - Section 18 - Subsection 18(5) - Specified Right pledged term deposit could be specified right
2014-03-19 30 January 2014 External T.I. 2013-0515761E5 F - Dividend received General Concepts - Payment & Receipt book entries merely record and do not establish that a dividend was paid
Income Tax Act - Section 82 - Subsection 82(1) - Paragraph 82(1)(a) book entries are ancillary and do not establish receipt
2014-03-05 4 December 2013 External T.I. 2012-0465891E5 F - Primes d'assurance / Premiums Income Tax Act - Section 15 - Subsection 15(1) insurance premium benefits qua shareholder
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) sub plan with only one employee of particular employer could be a group plan if benefits similar to those for employees in other sub plans
2014-02-26 7 February 2014 External T.I. 2014-0516921E5 F - Crédit et frais résiduels Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property lease/sale distinction established based on the legal relationship
Income Tax Act - Section 6 - Subsection 6(2) employer potentially can choose to prorate terminal credits or deficiencies (based on sale price on car lease termination relative to residual value) in applying formula
General Concepts - Substance lease characterized as lease unless its actual legal effects differ
Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A lease under which lessee bore all risk implicitly treated as lease rather than purchase
23 December 2013 External T.I. 2013-0505481E5 F - Application des paragraphes 6(6) et 110.7(1) Income Tax Act - 101-110 - Section 110.7 - Subsection 110.7(1) interaction between ss. 6(6) and 110.7(1)(b)
Income Tax Act - Section 6 - Subsection 6(6) Treasury Board rates considered to be reasonable
2014-02-19 19 December 2013 External T.I. 2012-0468851E5 F - Deduction for Insolvency Income Tax Act - Section 61.3 - Subsection 61.3(3) maximizing deduction through debt parking with parent rather than simple settlement subject to s. 61.3(3)