6 more translated CRA interpretations are available

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

These are additions to our set of 1,017 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 2/3 years of releases of Interpretations by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. You are currently in the “open” week for December.

Bundle Date Translated severed letter Summaries under Summary descriptor
2011-05-06 13 April 2010 External T.I. 2010-0382791E5 F - Logement offert gratuitement à un pasteur Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) occupation of free housing after ceased to be pastor not taxable if not in exchange for services
2011-04-29 4 April 2011 External T.I. 2010-0388741E5 F - Société quittant le Canada Income Tax Act - Section 250 - Subsection 250(5.1) no requirement to file Canadian returns following continuance
22 March 2011 Internal T.I. 2010-0387551I7 F - Dépenses - travailleur indépendant Income Tax Regulations - Schedules - Schedule II - Class 8 - Paragrpah 8(i) erotic costumes used on website did not qualify
Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(h) expenses of costumes, breast implants and rejuvenation expenses of erotic website were non-deductible
2011-04-22 8 October 2010 Roundtable, 2010-0373201C6 F - Change of Control and Amalgamation Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(a) CRA will respect out-of-ordinary course transactions that logically occur between AOC and amalgamation as being effected by predecessor
2011-04-08 30 March 2011 External T.I. 2010-0390591E5 F - Cotisation spéciale Income Tax Act - Section 9 - Timing amounts assessed against the taxpayer by co-owners not deductible until expended on or in the business
Income Tax Act - Section 248 - Subsection 248(16) - Paragraph 248(16)(a) - Subparagraph 248(16)(a)(i) addition for GST and subtraction for ITC
General Concepts - Payment & Receipt amounts paid by set-off are both paid even though no movement of funds
8 October 2010 Roundtable, 2010-0373501C6 F - Al. 212(9)d) proposé - remboursement Income Tax Act - Section 212 - Subsection 212(9) - Paragraph 212(9)(d) need for alteration of 2-year limitation in s. 227(5) in order to recover tax back to 2000