6 further translations of CRA interpretations are available

5 February 2019 - 12:39am
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We have published a further 6 translations of interpretations released in October and September 2012. Their descriptors and links appear below.

These are additions to our set of 771 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ½ years of releases by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. You are currently in the “open” week for February.

Bundle Date Translated severed letter Summaries under Summary descriptor
2012-10-10 6 July 2012 Internal T.I. 2012-0453461I7 F - rental losses Canada-France Treaty Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit no requirement to establish reasonable expectation of profit re deducting loss from French rental property if no personal element
Treaties - Income Tax Conventions - Article 24 s. 126(1) FTC re French income tax on rental income
2012-10-03 17 July 2012 Internal T.I. 2012-0454701I7 F - Arrière-arrière-grand-père Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Share of the Capital Stock of a Family Farm or Fishing Corporation - Paragraph (a) - Subparagraph (a)(iii) farm use by great-great-grandparent did not qualify the property, cf. great-grandparent
Income Tax Act - Section 252 - Subsection 252(2) - Paragraph 252(2)(a) parent in s. 110.6 context includes great-grandparent but not great-great-grandparent
2012-09-14 4 July 2012 External T.I. 2011-0429601E5 F - Roulement et société de personnes Income Tax Act - Section 98 - Subsection 98(3) two partnerships potentially could be merged by using s. 97(2) followed by s. 98(3), or the reverse
Income Tax Act - Section 97 - Subsection 97(2) partnership is taxpayer for purposes of s. 97(2), which might be used with s. 98(3)
30 July 2012 External T.I. 2011-0421801E5 F - Choix aux paragraphes 70(2) et 70(3) Income Tax Act - Section 70 - Subsection 70(2) if desire for s. 70(3) to apply, a timely revocation of s. 70(2) election can be made
Income Tax Act - Section 70 - Subsection 70(3) application of s. 70(3) re deceased’s share of partnership WIP is at estate’s choice
2012-08-31 14 August 2012 External T.I. 2012-0450041E5 F - subsection 55(4) Income Tax Act - Section 55 - Subsection 55(4) s. 55(4) not engaged where transactions eliminate shareholdings but not unrelated status of unrelated person
Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(ii) s. 55(3)(a)(ii) exclusion avoided by distributing shares out of unrelated-person trust
15 August 2012 External T.I. 2012-0444461E5 F - Pompiers volontaires Income Tax Act - Section 118.06 - Subsection 118.06(1) not a “volunteer” if paid more than a minimal amount or minimum hours are required
Income Tax Act - Section 81 - Subsection 81(4) “volunteer firefighter” has the same meaning as in s. 118.96(1)