6 further full-text translations of CRA interpretations are available
18 February 2019 - 11:35pm
Email this ContentWe have published a further 6 translations of interpretations released in August and July 2012. Their descriptors and links appear below.
These are additions to our set of 783 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 2/3 years of releases by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall.
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2012-08-24 | 30 July 2012 Internal T.I. 2012-0436711I7 F - Reassessment beyond the normal reassessment period | Income Tax Act - Section 152 - Subsection 152(4) - Paragraph 152(4)(a) - Subparagraph 152(4)(a)(i) | CRA could reassess beyond normal reassessment period based solely on an ARQ audit report showing error and carelessness of the taxpayer |
| 2012-08-10 | 3 July 2012 External T.I. 2012-0443421E5 F - 84.1 and partnership | Income Tax Act - Section 245 - Subsection 245(4) | s. 245(2) has been applied to the use of a partnership to avoid s. 84.1 |
| Income Tax Act - Section 84.1 - Subsection 84.1(1) | use of partnership to avoid s. 84.1 could be attacked through challenge to partnership validity or applying s. 245(1) re circumvention of s. 84.1 | ||
| 13 July 2012 External T.I. 2012-0443281E5 F - DPA- véhicule dans le cadre d'un bien locatif | Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) | CCA could be claimable on motor vehicle used to earn rental income | |
| 2012-07-20 | 9 July 2012 External T.I. 2012-0438751E5 F - Police d'assurance-vie | Income Tax Act - Section 148 - Subsection 148(9) - Proceeds of Disposition | proceeds of disposition arise when policy settled and are calculated by insurer |
| Income Tax Act - Section 237 - Subsection 237(1.1) | provision of SIN by holder of matured policy to insurer is required | ||
| 2012-07-06 | 28 June 2012 External T.I. 2011-0427871E5 F - Application des paragraphes 98(3) 98(5) et 73(1) | Income Tax Act - Section 73 - Subsection 73(1) | s. 73(1) available on transfer of undivided interest from one separate spouse to the other following s. 98(3) wind-up of their rental partnership |
| Income Tax Act - Section 98 - Subsection 98(5) | rental operation generating property income is a business for s. 98(5) purposes | ||
| 26 June 2012 External T.I. 2011-0417391E5 F - Bien remis à une fiducie | Income Tax Act - 101-110 - Section 108 - Subsection 108(1) - Testamentary Trust | being a contingent beneficiary of an inter vivos trust disqualified a testamentary trust as such | |
| Income Tax Act - Section 248 - Subsection 248(25) | testamentary trust that was included in the class of potential beneficiaries of a discretionary inter vivos trust was a beneficiary |