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

30 January 2018 - 12:32am
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The table below provides descriptors and links for four French technical interpretations released in January 2014 and three question from the October 2013 APFF Roundtable, as fully translated by us.

These (and the other full-text translations covering the last 4 years of CRA releases) are subject to the usual (3 working weeks per month) paywall. Next week is the ”open” week for February.

Bundle Date Translated severed letter Summaries under Summary descriptor
2014-01-29 11 October 2013 Roundtable, 2013-0495591C6 F - Déplacement entre résidence et chantier Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h.1) employer-requested travel to and from employee’s residence and a non-usual place of work is non-personal
5 June 2013 Internal T.I. 2013-0490941I7 F - Expenses for food 67.1(1) Income Tax Act - Section 67.1 - Subsection 67.1(1) AD-98-24 (respecting allocation of construction-worker living allowances to food) still in effect
11 October 2013 Roundtable, 2013-0495701C6 F - Financement participatif Income Tax Act - Section 9 - Nature of Income crowdfunding amounts received by an entrepreneur are prima facie business income
11 October 2013 APFF Roundtable, 2013-0495651C6 F - Revenu fractionné Income Tax Act - Section 120.4 - Subsection 120.4(1) - Split Income - Paragraph (c) streaming of non-split income to child discretionary beneficiary and split income to mother
Income Tax Act - 101-110 - Section 104 - Subsection 104(13) streaming of split and non-split income between trust beneficiaries
2014-01-22 6 January 2014 External T.I. 2013-0512041E5 F - Dividend Designation under subsection 89(14) Income Tax Act - Section 89 - Subsection 89(14) designation can be on all (rather than just part) of the dividend
3 January 2014 External T.I. 2013-0514021E5 F - Subsection 55(2) - redemption of shares Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) dividend recipient unrelated to nephew's company; "small" percentage not "significant;" previous estate freeze might be part of series
18 December 2013 External T.I. 2011-0414841E5 F - All interests vested indefeasibly Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Trust - Paragraph (g) s. 75(2) trust made non-discretionary to avoid 21-year rule