6 more translated CRA interpretations are available

17 December 2019 - 12:03am
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We have published a further 6 translations of CRA interpretations released in April and March, 2011, including 3 items from the 2010 APFF Roundtable. Their descriptors and links appear below.

These are additions to our set of 1,029 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 8 ¾ years of releases of Interpretations 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
2011-04-01 8 October 2010 Roundtable, 2010-0373211C6 F - Butterfly Transaction - Permitted Exchange Income Tax Act - Section 55 - Subsection 55(1) - Permitted Exchange - Paragraph (b) issuance of shares by TC after the DC distribution not relevant to there being “permitted exchange”
Income Tax Act - Section 55 - Subsection 55(3.1) - Paragraph 55(3.1)(b) issuance of shares by TC after the DC distribution without AOC of TC does not engage s. 55(3.1)(b)
8 October 2010 Roundtable, 2010-0373241C6 F - Acquisition of Control Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(d) question of fact whether somersault transaction results in acquisition of control of a public company
Income Tax Act - Section 256 - Subsection 256(6.1) purpose is to take into account simultaneous control at the various levels
2011-03-25 16 March 2011 External T.I. 2010-0380571E5 F - Application de 251(5)b)(ii) et 256(1.4)b) Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(ii) s. 251(5)(b)(ii) does not apply where corporation is required to redeem shares of declared fraudster
Income Tax Act - Section 256 - Subsection 256(1.4) - Paragraph 256(1.4)(b) potential application even where no control over triggering of precondition
8 October 2010 Roundtable, 2010-0370481C6 F - Don, vente d'actions acquises en vertu 7(1) Income Tax Act - 101-110 - Section 110 - Subsection 110(2.1) donation funded with proceeds of short hedge put on immediately on s. 7 exercise does not qualify
Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d.01) cashless exercise does not satisfy ss. 110(2.1) and 110(1)(d.01)
3 March 2011 External T.I. 2010-0379181E5 F - Jeux de hasard sur Internet Income Tax Act - Section 248 - Subsection 248(1) - Business on-line poker winnings would be non-taxable if absence of conduct of serious business person
Income Tax Act - Section 3 - Business Source/Reasonable Expectation of Profit on-line poker winnings generally non-taxable
22 March 2011 External T.I. 2010-0391131E5 F - Gains ouvrant droit à pension - RPC/RRQ Income Tax Regulations - Regulation 200 - Subsection 200(1) zero should be entered in Box 26 re QPP if employee under 18