6 further full-text translations of CRA interpretations are available

26 February 2019 - 12:45am
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We have published a further 6 translations of interpretations released in July and June 2012. Their descriptors and links appear below.

These are additions to our set of 789 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 6 ¾ years of releases by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. Next week is the “open” week for March.

Bundle Date Translated severed letter Summaries under Summary descriptor
2012-07-06 26 June 2012 Internal T.I. 2012-0436381I7 F - Nature d’un revenu - Indemnité d’assurance Income Tax Act - Section 129 - Subsection 129(6) insurance proceeds in lieu of rents from associated corp did not qualify under s. 129(6)
Income Tax Act - Section 9 - Compensation Payments life insurance proceeds for rental property did not have the character of rents from an associated corp
2012-06-29 14 June 2012 External T.I. 2011-0428341E5 F - Crédit activités physiques, activités artistiques Income Tax Act - Section 63 - Subsection 63(3) - Child Care Expense expenses that qualified for the child fitness or children's arts tax credit potentially could qualify as child care expenses
2012-06-22 5 June 2012 External T.I. 2011-0417971E5 F - Sociétés associées - CII Income Tax Act - Section 127 - Subsection 127(10.2) computation of expenditure limit where one CCPC acquires another
15 June 2012 External T.I. 2012-0434761E5 F - Dons liés à une police d'assurance-vie Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts gift if pay policy premiums following assignment of policy to charity, but not by virtue of designating charity as policy beneficiary
Income Tax Act - Section 248 - Subsection 248(31) donated life insurance policy to be valued on ordinary principles
General Concepts - Fair Market Value - Other 7 factors to be considered in valuing a donated life insurance policy
13 June 2012 External T.I. 2011-0416781E5 F - Entente contractuelle particulière Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) intragroup charges to reflect use of each other’s capital under cash pooling arrangement are non-deductible
13 June 2012 Internal T.I. 2012-0435351I7 F - SEPE - chèques en circulation Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation outstanding and uncashed cheques did not reduce cash
General Concepts - Payment & Receipt in Quebec, payment by cheque does not occur until debiting of bank account