6 more translated CRA interpretations are available

10 June 2019 - 11:37pm
Email this ContentEmail this Content

We have published a further 6 translations of CRA interpretations released in January 2012 and December 2011. Their descriptors and links appear below.

These are additions to our set of 879 full-text translations of French-language Rulings, Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 7 1/2 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
2012-01-27 4 January 2012 Internal T.I. 2011-0408081I7 F - Transactions entre une société et ses actionnaires Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) - Subparagraph 13(7)(e)(i) s. 13(7)(e)(i) capital cost equals consideration paid even where in excess of FMV
2012-01-20 13 January 2012 Internal T.I. 2011-0414111I7 F - Deemed Interest Incomes - Exception 17(8) Income Tax Act - Section 17 - Subsection 17(8) - Paragraph 17(8)(a) - Subparagraph 17(8)(a)(ii) CFA 1's purchased debt of CFA 2 did not qualify as a loan or advance
4 January 2012 External T.I. 2011-0414731E5 F - Interaction between 84.1 and 83(2) ITA Income Tax Act - Section 83 - Subsection 83(2) no s. 83(2) election available for s. 84.1(1)(b) deemed dividend paid to non-shareholder
Income Tax Act - Section 84 - Subsection 84(7) s. 84(7) might contradict CRA position that no s. 83(2) election on s. 84.1 dividend to non-shareholder
2012-01-13 16 December 2011 External T.I. 2011-0419211E5 F - Choix à 45(2) Income Tax Act - Section 45 - Subsection 45(2) devisee of changed-use principal residence cannot benefit from s. 45(2) election by estate in years following testator’s death
2011-12-30 16 December 2011 External T.I. 2011-0412502E5 F - Remboursement - frais de scolarité Income Tax Act - Section 118.1 - Subsection 118.1(5) - Paragraph 118.1(5)(a) - Subparagraph 118.1(5)(a)(iii) credit can be claimed where employee is subsequently required to reimburse employer for employer-paid tuition
Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program no benefit denying credit if employee is subsequently required to reimburse employer for employer-paid tuition
21 November 2011 External T.I. 2011-0422191E5 F - Price adjustment clause and redemption of shares General Concepts - Effective Date additional payment, pursuant to price adjustment clause, in year following shares; redemption is recognized then
Income Tax Act - Section 84 - Subsection 84(3) price adjustment payment recognized as s. 84(3) dividend when received