6 more translated CRA interpretations are available

12 August 2019 - 11:44pm
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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 November, 2011 (all of them, from the October 2011 APFF Roundtables). Their descriptors and links appear below.

These are additions to our set of 933 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers the last 7 3/4 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
2019-08-07 11 June 2019 External T.I. 2019-0795291E5 F - Tax on Split Income - 120.4(1) excluded amount Income Tax Act - Section 120.4 - Subsection 120.4(1) - Related Business no TOSI tax applied to a dividend received from the surviving step-mother’s company
Income Tax Act - Section 120.4 - Subsection 120.4(1) - Excluded Amount - Paragraph (e) - Subparagraph (e)(i) dividend received from widowed step-mother's company was not re a related business
2011-11-04 7 October 2011 Roundtable, 2011-0412041C6 F - Accumulated Profits for 20(1)(c) Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) appraisal increment excluded from accujulated profits
7 October 2011 Roundtable, 2011-0407291C6 F - Group Life Insurance Policy Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) - Subparagraph (d)(ii) CDA addition for receipt of proceeds of policy on life of shareholder
Income Tax Act - Section 15 - Subsection 15(1) s. 15(1) could possibly apply where a professional corporation pays the premiums, and is designate the beneficiary, of a policy in name of professional
7 October 2011 Roundtable, 2011-0411941C6 F - Covoiturage Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) employees and employer must reasonably allocate benefit from gas carpooling expenses being reimbursed
7 October 2011 Roundtable, 2011-0411961C6 F - Dépenses de déplacement Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(b) - Subparagraph 6(6)(b)(i) s. 6(6)(b)(i) extended to a temporary foreign principal place of residence
7 October 2011 Roundtable, 2011-0413281C6 F - Avantage à un actionnaire et assurance-vie Income Tax Act - Section 15 - Subsection 15(1) s. 15(1) benefit where corporation switches the life insurance policy beneficiary to a shareholder may not be based on premiums paid if death impendng