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

5 February 2018 - 11:18pm
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The table below provides descriptors and links for six French technical interpretation released in January of 2014, 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. You are currently in the “open” week for February.

Bundle Date Translated severed letter Summaries under Summary descriptor
2014-01-22 9 December 2013 External T.I. 2013-0507931E5 F - Financing fees Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e) cash pool utilization fees could be deductible under s. 20(1)(e)
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures intragroup cash pool utilization fees are capital expenditures
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.1) annual internal cash pool utilization fees likely are deductible under s. 20(1)(e.1)
2014-01-15 30 October 2013 External T.I. 2013-0500831E5 F - Frais de bureau à domicile Income Tax Act - Section 8 - Subsection 8(13) inapplicable where corporation uses its individual shareholder's office
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose to deduct applicable home expenses, individual shareholder must charge rent to corporation using home office
Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) incidental rental use of home does not result in part disposition
15 October 2013 External T.I. 2013-0498001E5 F - Transfert de sommes inutilisées entre régimes Income Tax Act - Section 248 - Subsection 248(1) - Private Health Services Plan transfer from individual healthcare spending account to another PHSP is permitted
18 December 2013 External T.I. 2013-0479421E5 F - Section 30 and Cranberry Farm Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense initial cranberry plant planting is a cost of land
Income Tax Act - Section 30 costs of clearing, levelling and draining lands, but not of constructing basins, for a cranberry farm are currently deductible
Income Tax Regulations - Schedules - Schedule II - Class 17 costs of constructing cranberry farm basins included in Class 17
Income Tax Regulations - Schedules - Schedule II - Class 6 costs of constructing irrigation pond included
Income Tax Regulations - Schedules - Schedule II - Class 8 irrigation system included, drainage costs deductible under s. 30
28 November 2013 External T.I. 2013-0504221E5 F - Fin d'années réputées Income Tax Act - Section 249 - Subsection 249(3.1) Amalco not a continuation of predecessors for election purposes
8 October 2013 External T.I. 2011-0428931E5 F - Assurance-invalidité Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose non-deductibility of disability insurance premiums
Income Tax Act - Section 9 - Exempt Receipts/Business proceeds received as a result of business credit card insurance were not income