6 further full-text translations of CRA interpretations are available

15 May 2018 - 12:45am
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The table below provides descriptors and links for the Technical Interpretation released last week, a further Technical Interpretation also provided by us last week (which has not yet been released under the severed letter program, hence the absence of a bundle date) and four Technical Interpretations released in October 2013, all as fully translated by us.

The above translated interpretations (and the other full-text translations covering the last 4 1/2 years of CRA releases) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
TBA 1 May 2018 External T.I. 2017-0709101E5 F - Travaux en cours et nouvelles regies suite au budget Income Tax Act - Section 10 - Subsection 10(1) professionals' WIP excludes partner time but includes variable overhead
Income Tax Act - Section 10 - Subsection 10(5) - Paragraph 10(5)(a) cost of professional practice WIP includes variable overheads and all related payroll costs, but not partner or shareholder-manager time
Income Tax Act - Section 10 - Subsection 10(4) - Paragraph 10(4)(a) WIP under a contingency fee basis generally has a nil value
2018-05-09 26 March 2018 External T.I. 2017-0734381E5 F - Election paragraph 34(a) Income Tax Act - Section 34 a subsequently admitted partner benefits from a s. 34 WIP election made for a professional partnership’s 2017 year
Income Tax Act - Section 10 - Subsection 10(14.1) transitional rule applies to assignee partner
2013-10-02 8 July 2013 Internal T.I. 2012-0434991I7 F - Déductibilité d'une perte Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(p) - Subparagraph 20(1)(p)(ii) ordinary business requirement looks to the presence of an organized and continuous system
Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) per jurisprudence on guarantees, taxpayer’s reason for assuming an obligation (to protect an interest-bearing investment) must be examined
4 September 2013 Internal T.I. 2013-0497401I7 F - Remboursement partiel de frais d'abonnement Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) generally a taxable benefit where reimbursement of fitness centre membership fees
28 August 2013 Internal T.I. 2013-0496861I7 F - Allocation de résidence pour les juges Income Tax Act - Section 6 - Subsection 6(6) exemption was potentially available for a housing allowance received by a Chief Justice or Associate Chief Justice under a temporary appointment
8 July 2013 Internal T.I. 2012-0472651I7 F - Crédit pour l'embauche par les petites entreprises Income Tax Act - Section 9 - Exempt Receipts/Business small business job credit received for payroll of non-business employees, exempt
Income Tax Act - Section 118.2 - Subsection 118.2(3) - Paragraph 118.2(3)(b) small business job credit received for personal-care workers was “reimbursement”
Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(b.1) single service does not qualify as attendant care