Six further full-text translations of CRA interpretations are available

5 June 2018 - 12:08am
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The table below provides descriptors and links for six Technical Interpretation released in August and September 2013, as fully translated by us.

These (and the other full-text translations covering all “French” Interpretations released in the last 4 3/4 years by the Income Tax Rulings Directorate) are subject to the usual (3 working weeks per month) paywall. You are currently in the open week for June.

Bundle Date Translated severed letter Summaries under Summary descriptor
2013-09-04 28 March 2013 External T.I. 2012-0465171E5 F - Frais médicaux - technicien en orthophonie Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(a) services of speech therapy technician ineligible
Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(l.9) services of speech therapy technician, who supplemented speech-language pathologist’s services, were ineligible as being unsupervised by a doctor
Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(o) services of speech therapy technician did not assist in diagnosis
23 April 2013 Internal T.I. 2012-0466081I7 F - Usufruct created under French legislation Income Tax Act - Section 43.1 gift of immovable subject to reservation of a usufruct gave rise to a disposition under s. 43.1
Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) disposition of all building under shared gift
General Concepts - Foreign Law 2-step approach to characterizing a French civil law transaction
13 March 2013 Internal T.I. 2013-0480511I7 F - Canadian resource property Income Tax Act - Section 66 - Subsection 66(15) - Canadian Resource Property government agency charge for its costs in conducting environmental assessment before granting exploration permit were included in CDE
15 April 2013 Internal T.I. 2012-0471161I7 F - Avantage imposable - Taxable Benefit Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) lifetime transportation passes to retired bus company directors are non-taxable
2013-08-21 8 August 2013 External T.I. 2013-0477461E5 F - Foreign Tax Credit under 126(2) of ITA Income Tax Act - Section 126 - Subsection 126(2) taxes paid by non-resident parent on behalf of Canco re foreign country income tax on Canco’s foreign branch profits in that country could be creditable
2013-08-14 26 June 2013 External T.I. 2013-0490711E5 F - Disposition en contrepartie de 1$ Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) nature of Quebec gift