6 more translated CRA interpretations are available

16 April 2019 - 12:20am
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We have published a translation of a CRA interpretation released last week and a further 5 translations of CRA interpretations released in March 2012. Their descriptors and links appear below.

These are additions to our set of 831 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.

Bundle Date Translated severed letter Summaries under Summary descriptor
2019-04-10 2 April 2019 Internal T.I. 2016-0649821I7 F - Unclaimed superannuation or pension benefits Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(a) - Subparagraph 56(1)(a)(i) subsequent year’s payment of benefit to a previously-unidentified beneficiary is only income in that year as an “in lieu of” pension amount
General Concepts - Payment & Receipt amount received in Year 2 in lieu of pension benefit includes source deductions in Year 1
2012-03-30 12 March 2012 External T.I. 2011-0425361E5 F - Assistance paid by franchisor Income Tax Act - Section 9 - Exempt Receipts/Business reimbursements of business expenses increase income
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) contest awards paid to franchisees includible under s. 12(1)(x) if not under s. 9
8 March 2012 External T.I. 2011-0426061E5 F - Bien agricole admissible Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1.3) - Paragraph 110.6(1.3)(c) land that had been farmed for 5 years before being rented out to neighbouring farmer qualified, including farm house
21 March 2012 External T.I. 2011-0423141E5 F - Application du paragraphe 107(4.1) Income Tax Act - 101-110 - Section 107 - Subsection 107(4.1) - Paragraph 107(4.1)(c) s. 107(4.1) applied to distribution to settlor/beneficiary of property acquired with borrowed money
20 March 2012 External T.I. 2011-0424461E5 F - Déduction d'une rétribution à un agent immobilier Income Tax Act - Section 9 - Timing commissions paid for leasing-up a new building generally are fully and currently deductible
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Improvements v. Repairs or Running Expense lease-up commissions were current expenses
16 March 2012 External T.I. 2011-0423191E5 F - Disposition d'une participation dans une SP Income Tax Act - Section 98 - Subsection 98(1) disposition of partnership interest for nil proceeds when partnership dissolved upon winding-up distribution
Income Tax Act - Section 248 - Subsection 248(1) - Disposition - Paragraph (b) - Subparagraph (b)(i) disposition of partnership interest even though no proceeds received