4 more translated CRA interpretations are available

6 January 2020 - 11:51pm
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We have published a further 4 translations of CRA interpretations released in March, 2011. Their descriptors and links appear below.

These are additions to our set of 1,058 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. You are currently in the “open” week for January.

Bundle Date Translated severed letter Summaries under Summary descriptor
2011-03-11 8 October 2010 Roundtable, 2010-0373461C6 F - Retrait d'une société de personnes Income Tax Act - Section 40 - Subsection 40(3) negative ACB realized pro rata as units are redeemed
Income Tax Act - Section 100 - Subsection 100(2) negative ACB realized pro rata under s. 100(2) as portion of the units are redeemed each year
Income Tax Act - Section 43 - Subsection 43(1) all the partner’s units are a single property
Income Tax Act - Section 248 - Subsection 248(1) - Property partnership unit is not separate property from other units
8 October 2010 Roundtable, 2010-0373221C6 F - Paid-up capital Income Tax Act - Section 89 - Subsection 89(1) - Paid-Up Capital - Paragraph (a) abusive use of PUC averaging to shift PUC to individuals
Income Tax Act - Section 245 - Subsection 245(3) - Paragraph 245(3)(a) transaction can be an avoidance transaction even where the series is motivated by business reasons
Income Tax Act - Section 245 - Subsection 245(4) CRA has concluded in some cases that using PUC averaging to shift PUC to individual shareholders engages GAAR
8 October 2010 Roundtable, 2010-0373641C6 F - frais juridiques engagés par des conjoints de fait Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees legal costs incurred by common-law partners to negotiate support are non-deductible
14 September 2010 External T.I. 2010-0372631E5 F - Bien agricole admissible Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1.3) - Paragraph 110.6(1.3)(b) condition could be satisfied by husband for two-year period before his decease