6 more translated CRA interpretations are available

21 May 2019 - 12:54am
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We have published translations of 6 CRA interpretations released in March and February, 2012. Their descriptors and links appear below.

These are additions to our set of 861 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 7 ¼ 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
2012-03-02 10 February 2012 External T.I. 2010-0385861E5 F - Actions de remplacement Income Tax Act - Section 44.1 - Subsection 44.1(1) - Replacement Share application to IPO of CCPC
Income Tax Act - Section 44.1 - Subsection 44.1(1) - Qualifying Disposition elements of qualifying disposition definition
2012-02-24 23 January 2012 External T.I. 2011-0409671E5 F - Propriété superficiaire Income Tax Act - Section 54 - Principal Residence - Paragraph (e) land leased to corporation for business use not part of principal residence
Income Tax Act - Section 15 - Subsection 15(1) benefit if building constructed at corporation’s expense for business purposes becomes shareholder’s property by accession
Income Tax Regulations - Regulation 1102 - Subsection 1102(1) - Paragraph 1102(1)(c) individual shareholder not entitled to claim CCA on building constructed by the corporation for use in its business even if where taxpayer owns it
General Concepts - Ownership whether tenant had Quebec right of superficies to garage erected by it determined whether it was its property
Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property building erected by corporation on shareholder’s land not depreciable property unless shareholder renounces right of accession
6 February 2012 External T.I. 2012-0434071E5 F - Honoraires professionnels - PDV Income Tax Act - Section 60 - Paragraph 60(o) professional fees incurred under VDP are deductible under s. 60(o) once CRA commences its review
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees professional fees incurred in applying under the VDP are not deductible
14 February 2012 External T.I. 2011-0416621E5 F - REER, swap Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) computation of advantage from swap transaction
Income Tax Act - Section 207.01 - Subsection 207.01(1) - RRSP Strip swap of savings bond between RRSP and non-registered account would be an RRSP strip
9 February 2012 Internal T.I. 2011-0426871I7 F - Perte au titre d'un placement d'entreprise Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) - Subparagraph 39(1)(c)(iv) requirement satisfied where debtor reacquired its status as SBC before becoming bankrupt
2012-02-17 9 February 2012 External T.I. 2008-0280941E5 F - Foreign sourced income - transportation Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(b) s. 4(1)(b) generally applied on a jurisdictional basis
Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) incidental business activities in jurisdiction may not constitute carrying on business there
Income Tax Act - Section 126 - Subsection 126(9) s. 4(1)(b) applied for s. 126(9) purposes
Income Tax Act - Section 126 - Subsection 126(7) - Business-Income Tax NY franchise tax qualified as an income tax only if it was not based on non-income specified minimums