Over 600 translations of CRA French-language interpretations are available
30 July 2018 - 11:08pm
Email this ContentThe table below provides descriptors and links for six Interpretation released in May and June 2013, as fully translated by us.
These (and the other full-text translations covering all of the 609 French-language Interpretations released in the last 5 1/4 years by the Income Tax Rulings Directorate) are subject to the usual (3 working weeks per month) paywall. Next week is the "open" week for August.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2013-06-12 | 20 March 2013 External T.I. 2012-0442571E5 F - Coût d'acquisition d'un terrain | Income Tax Regulations - Schedules - Schedule II - Class 8 | cost of water and sewer lines connecting mobile home units, included in Class 8 |
| Income Tax Act - Section 54 - Adjusted Cost Base | cost of land acquired from developer equal to total barter value minus amounts allocated to Classes 8 and 17 | ||
| 9 January 2013 External T.I. 2010-0384221E5 F - Paiements indirects | Income Tax Act - Section 56 - Subsection 56(2) | cost of land acquired from developer equal to total barter value minus amounts allocated to Classes 8 and 17 | |
| 14 February 2013 Internal T.I. 2011-0424341I7 F - Amounts forwarded to trustee/beneficiary | Income Tax Act - Section 75 - Subsection 75(2) | s. 75(2) not applicable to dividends on common shares issued to discretionary family trust on estate freeze | |
| Income Tax Act - Section 56 - Subsection 56(2) | s. 56(2) did not apply to trustee/beneficiary of discretionary trust who directed income to her children and did not exercise discretion in her own favour | ||
| Income Tax Act - 101-110 - Section 104 - Subsection 104(13) | income was received by children beneficiaries as agent for their mother | ||
| Income Tax Act - 101-110 - Section 104 - Subsection 104(6) - Paragraph 104(6)(b) | Quebec discretionary trust with two named trustees but, in fact, only one trustee, would not be entitled to s. 104(6)(b) deductions | ||
| 2013-06-05 | 12 February 2013 Internal T.I. 2012-0437211I7 F - NRT rules and subsection 164(6) | Income Tax Act - Section 164 - Subsection 164(6) | s. 94 deemed resident trust could carry back under s. 164(6) re capital loss on non-TCP shares |
| Income Tax Act - Section 54 - Personal-Use Property | personal residence of deceased potentially would not be personal-use property to estate | ||
| Income Tax Act - Section 94 - Subsection 94(3) - Paragraph 94(3)(a) | estate of resident deceased with one resident beneficiary was subject to s. 94(3) | ||
| 2013-05-29 | 17 April 2013 External T.I. 2012-0457011E5 F - Coop Shares in RRSP and Prohibited Invest. Rules | Income Tax Act - Section 207.01 - Subsection 207.01(1) - Excluded Property - Paragraph (c) | shares can become prohibited investments as a result of other shareholders dispose of their shares |
| Income Tax Act - Section 207.04 - Subsection 207.04(4) | dispositions that generate the refund are not limited to redemptions of the shares | ||
| Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (c) | advantage tax on net capital gains and income of RRSP from cooperative shares | ||
| 2013-05-15 | 5 April 2013 External T.I. 2012-0471151E5 F - Binding Agreement | Income Tax Act - Section 9 - Computation of Profit | side letter would not reduce owner’s entitlement to rents from property if not entered into at same time as property acquisition |
| Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense | counter letter payments non-deductible because Quebec counter letter entered into after apparent letter |