6 more translated CRA interpretations are available

6 May 2019 - 11:58pm
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We have published translations of a CRA interpretation released last week and a further 5 released in March 2012. Their descriptors and links appear below.

These are additions to our set of 849 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. You are currently in the “open” week for April.

Bundle Date Translated severed letter Summaries under Summary descriptor
2019-05-01 28 March 2019 External T.I. 2019-0799241E5 F - Dépenses d'emploi (employé qui n'est pas à commission) Income Tax Act - Section 8 - Subsection 8(13) home office expenses generally cannot include property taxes or insurance
Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(i) - Subparagraph 8(1)(i)(ii) property taxes and insurance expenses of home office do not qualify
2012-03-09 28 February 2012 External T.I. 2011-0424191E5 F - Fiscal period of a partnership Income Tax Act - Section 249.1 - Subsection 249.1(2) "share of ... income" references contractual entitlement irrespective of actual partnership income quantum
29 February 2012 External T.I. 2011-0431131E5 F - Sommes versées en règlement d'un grief Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance damages for event occurring during employment generally will be non-taxable
Income Tax Act - Section 5 - Subsection 5(1) damages on retroactive reinstatement are taxable
Income Tax Act - Section 60 - Paragraph 60(j.1) - Subparagraph 60(j.1)(v) previous employment years of service included if bought back
Income Tax Act - Section 60 - Paragraph 60(j.1) - Subparagraph 60(j.1)(ii)(B) employer contributions vest for each year bought back by an employee
24 February 2012 External T.I. 2011-0413311E5 F - Bien agricole admissible Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Farm or Fishing Property woodlot sale by father (who only had rented to son) to son likely qualified provided IT-373R2 farm v. logging operation, and s. 110.6(1.3)(b) gross revenue, tests satisfied
29 February 2012 External T.I. 2011-0427831E5 F - Chantier particulier Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(b) transportation allowance not excluded under s. 6(6)(b) if employee does not receive board and lodging
28 February 2012 External T.I. 2011-0420391E5 F - Prestations au décès Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit death benefit can be received by a former employee