We have 666 translations of CRA French-language interpretations!!

8 October 2018 - 11:37pm
Email this ContentEmail this Content

Well, 670 actually. The table below provides descriptors and links for six 2012 APFF Roundtable Interpretations as well as for an earlier interpretation (included somewhat out of sequence), all as fully translated by us.

These (and the other full-text translations covering all of the French-language Interpretations released in the last 5 2/3 years by the Income Tax Rulings Directorate) are subject to the usual (3 working weeks per month) paywall.

Bundle Date Translated severed letter Summaries under Summary descriptor
2013-02-06 5 October 2012 APFF Roundtable, 2012-0454061C6 F - Transfer of a Lossco to a related corporation General Concepts - Fair Market Value - Shares non-capital losses of corporation taken into account in valuing its shares
Income Tax Act - Section 111 - Subsection 111(1) - Paragraph 111(1)(a) related but not affiliated transfer of Lossco shares to father's or brother's company
Income Tax Act - Section 50 - Subsection 50(1) lossco with no assets or liabilities cannot be insolvent
Income Tax Act - Section 88 - Subsection 88(1.1) lossco losses maintained on father-son or sibling transfers and s. 88(1.1) wind-up
5 October 2012 APFF Roundtable, 2012-0454231C6 F - Garantie pour impôt de départ Income Tax Act - Section 220 - Subsection 220(4.5) CRA may accept shares of the CCPC shares generating departure tax and looks for a minimum 2:1 FMV/tax ratio
Income Tax Act - Section 220 - Subsection 220(4.53) partial redemption may not result in demand for payment of departure tax
5 October 2012 APFF Roundtable, 2012-0454241C6 F - Double imposition Income Tax Act - Section 160 - Subsection 160(2) ETA s. 325 assessment in same audit is issued after ITA s. 160 to avoid double tax/no priority accorded to ARQ
Excise Tax Act - Section 325 double taxation from contemporaeous ITA/ETA assessments avoided by ITA assessment being 1st
5 October 2012 APFF Roundtable, 2012-0453991C6 F - Action admissible de petite entreprise Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation Quebec partnership also transparent notwithstanding separate patrimony
5 October 2012 APFF Roundtable, 2012-0453591C6 F - Prêt à une fiducie Income Tax Act - Section 75 - Subsection 75(2) loan made to trust by sole trustee is not subject to s. 75(2) if not a contribution of capital
5 October 2012 APFF Roundtable, 2012-0454081C6 F - Statute-barred debt Income Tax Act - Section 80.01 - Subsection 80.01(9) question of fact whether a debt between related persons is extinguished upon the prescription period
2009-10-02 2 September 2009 Internal T.I. 2009-0329251I7 F - Application du paragraphe 80(16) Income Tax Act - Section 111 - Subsection 111(8) - Non-Capital Loss - A s. 61.3 deduction reduced non-capital loss
Income Tax Act - Section 80 - Subsection 80(13) s. 80(13) income was from a business
Income Tax Act - Section 80 - Subsection 80(16) s. 80(16) designation under s. 80(11) increased s. 80(13) income inclusion