Seven further full-text translations of CRA interpretations are available

20 March 2018 - 2:03am
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The table below provides descriptors and links for the French Technical Interpretation released last week, for two French Technical Interpretations released in November 2013 and for four questions from the October 2013 APFF Roundtable, as fully translated by us.

These (and the other full-text translations covering the last 4 1/3 years of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2018-03-14 18 December 2017 External T.I. 2017-0714971E5 F - Application of subsection 55(2) Income Tax Act - Section 55 - Subsection 55(2) relationship between Part IV tax and s. 55(2) and related amended return filings
Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b) s. 55(2) application does not reduce s. 186(1)(b) initially reported Pt IV tax
2013-11-27 11 October 2013 APFF Roundtable, 2013-0495861C6 F - Question 20 - APFF Round Table Income Tax Act - Section 248 - Subsection 248(1) - Specified Member specified member status determined re involvement in daily management or activities
11 October 2013 APFF Roundtable, 2013-0493671C6 F - Testamentary trust beneficiary of inter vivos trust Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Testamentary Trust testamentary trust will lose its status if it is designated as the beneficiary of an inter vivos trust
11 October 2013 APFF Roundtable, 2013-0492791C6 F - Gift by will Income Tax Act - Section 118.1 - Subsection 118.1(5) potential executor discretion re corporate/estate split of gift might preclude as "gift"
11 October 2013 APFF Roundtable, 2013-0495721C6 F - APFF 2013- Round table question 7 Income Tax Act - Section 75 - Subsection 75(2) Sommerer FMV sale exception maintained with price adjustment clause
General Concepts - Fair Market Value - Shares FMV is a question of fact within TCC's discretion
2013-11-20 7 October 2013 External T.I. 2013-0500941E5 F - Actif utilisé dans une entreprise active Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share rental property of partnership leased as to 15% to an active business partner did not qualify as active business asset
5 November 2013 External T.I. 2013-0501241E5 F - Application of subsection 39(2) Income Tax Act - Section 39 - Subsection 39(2) declared dividend is a debt to which s. 39(2) applies