Six further full-text translations of CRA interpretations are available
23 May 2018 - 1:28am
Email this ContentThe table below provides descriptors and links for a French Technical Interpretation released last week and for five Interpretations released in October and December of 2013, as fully translated by us.
These (and the other full-text translations covering the last 4 2/3 years of CRA releases) are subject to the usual (3 working weeks per month) paywall.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2018-05-16 | 12 April 2018 External T.I. 2016-0640651E5 F - Swiss Pension | Income Tax Act - Section 248 - Subsection 248(1) - superannuation or pension fund or plan | Swiss vested benefits policy was a “superannuation or pension fund or plan” |
| Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) | a Canadian resident was not subject to Canadian tax on income accruing in a Swiss vested benefits policy | ||
| 2013-10-02 | 10 April 2013 Internal T.I. 2013-0475991I7 F - Montant- période de raccordement | Income Tax Act - Section 5 - Subsection 5(1) | terminated employee treated as continuing to be an employee due to employer’s continued treatment as an employee for EI, CPP and RPP purposes |
| 2013-09-25 | 5 October 2012 Roundtable, 2012-0453231C6 F - Creditor's Group Life Insurance and CDA | Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) - Subparagraph (d)(ii) | Innovative case extended to individual policy: credit to borrowing CCPC’s CDA |
| 2013-09-11 | 13 August 2013 External T.I. 2012-0471401E5 F - FMV - partnership interest | General Concepts - Fair Market Value - Other | deferred tax liability re deferred (s. 34) partnership income recognition reduces partnership interest FMV |
| Income Tax Act - Section 85 - Subsection 85(1) - Paragraph 85(1)(c) | FMV of professional partnership interest would normally discount the value of s. 34-elected WIP for income taxes | ||
| Income Tax Act - Section 34 | FMV of partnership interest reduced re deferred income taxes on WIP subject to s. 34 election | ||
| 6 August 2013 External T.I. 2012-0469481E5 F - Benefit under trust | Income Tax Act - 101-110 - Section 105 - Subsection 105(1) | taxable benefit on sale to beneficiary at undervalue was not eliminated under s. 105(1)(a) when beneficiary sold the property | |
| Income Tax Act - Section 52 - Subsection 52(1) | benefit on estate sale to beneficiary at under-value added to property's ACB | ||
| Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | taxable benefit added to acb | ||
| 5 July 2013 Internal T.I. 2013-0489821I7 F - Application of subsection 18(3.1) | Income Tax Act - Section 18 - Subsection 18(3.1) | realty taxes or premiums related to land which is renovation object are capitalized |