6 more translated CRA interpretations are available

26 March 2019 - 12:19am
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We have published a further 6 translations of CRA interpretations released in April 2012 and (going somewhat out of sequence) April 2011. Their descriptors and links appear below.

These are additions to our set of 813 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 7 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 April.

Bundle Date Translated severed letter Summaries under Summary descriptor
2012-04-27 17 April 2012 External T.I. 2011-0427411E5 F - Bien de remplacement-immobilisation admissible Income Tax Act - Section 14 - Subsection 14(7) shares cannot be replacement property
17 April 2012 External T.I. 2012-0440931E5 F - Crédit d'impôt pour frais médicaux Income Tax Regulations - Regulation 5700 - Section 5700 - Paragraph 5700(i) motorized stationary bicycle did not qualify
2012-04-20 10 April 2012 External T.I. 2011-0428701E5 F - Lien de dépendance - commanditaire et SEC Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) limited partner at arm's length with LP if it has no management authority
10 April 2012 Internal T.I. 2011-0430291I7 F - Montant d'aide versé par la SAAQ à un conjoint Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit automobile insurance payments received for care of injured spouse were non-taxable
3 April 2012 External T.I. 2011-0426341E5 F - Catégories 29 et 43 Income Tax Regulations - Schedules - Schedule II - Class 29 scrap metal shearing device and container for sliced metal described in Class 29
2011-04-01 23 March 2011 Internal T.I. 2010-0389081I7 F - Disposition of a resource property Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (a) proceeds included full (undiscounted) deferred cash proceeds, but might exclude share consideration (with volatile market price) until issued
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(g) deferred share consideration potentially not recognized until issuance
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) full undiscounted amount of future cash consideration to be included as an amount receivable
Income Tax Act - Section 66.2 - Subsection 66.2(5) - cumulative Canadian development expense - Element F proceeds from mineral claims sale included undiscounted deferred cash proceeds, but might exclude share consideration until issued; purchaser’s CEE obligation excluded