Six further full-text translations of CRA interpretations are available

27 March 2018 - 1:07am
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The table below provides descriptors and links for a French Technical Interpretation released in November 2013 and for five questions from the October 2013 APFF Roundtables, 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. Next week is the “open” week for April.

Bundle Date Translated severed letter Summaries under Summary descriptor
2013-11-20 11 October 2013 Roundtable, 2013-0493701C6 F - Amount paid or credited - Reg. 202 Income Tax Regulations - Regulation 202 - Regulation 202(1) - Paragraph 202(1)(b) accounting method used by recipient does not affect which items are reported on NR4
23 September 2013 Internal T.I. 2012-0471531I7 F - Non-profit organization Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) taxable member of an NPO can make loans at interest to it and receive repayment of the loan on the NPO’s winding-up
2013-11-13 11 October 2013 Roundtable, 2013-0495271C6 F - Flow-through shares and death Income Tax Act - Section 66 - Subsection 66(12.66) lookback unavailable where taxpayer was deceased on December 31 of look-back year
Income Tax Act - Section 66 - Subsection 66(12.6) renunciation must take effect before the death of the deceased and is unavailable to estate
11 October 2013 Roundtable, 2013-0492821C6 F - Question 3 - APFF Round Table Treaties - Income Tax Conventions - Article 4 s. 94 trusts were resident in Canada for Treaty purposes even before Income Tax Conventions Interpretation Act amendment, which precludes application of tie-breaker
Other Legislation/Constitution - Federal - Income Tax Conventions Interpretation Act - Section 4.3 s. 4.3 precludes application of tie-breaker rule
11 October 2013 Roundtable, 2013-0495911C6 F - Insurable employment Other Legislation/Constitution - Federal - Employment Insurance Act - Section 5 - Subsection 5(2) - Paragraph 5(2)(b) employment by employees of partnership of corporations is treated as joint employment by those corporations
Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(a) partners treated as employers of partnership employees
11 October 2013 Roundtable, 2013-0495901C6 F - Limited partnership loss and non-capital loss Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss non-capital loss is not increased by amount otherwise deductible under s. 111(1)(e)