5 more translated CRA interpretations are available

We have published a further 5 translations of CRA interpretations released in March, 2011 (all of them, from the 2010 APFF Roundtable). Their descriptors and links appear below.

These are additions to our set of 1,078 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. Next week is the “open” week for February.

Bundle Date Translated severed letter Summaries under Summary descriptor
2011-03-04 8 October 2010 Roundtable, 2010-0373561C6 F - Régime de prestations aux employés et article 7 Income Tax Act - 101-110 - Section 107.1 - Paragraph 107.1(b) EBP rules do not apply where s. 7 applies to the plan
8 October 2010 Roundtable, 2010-0373371C6 F - Souscription des unités d'une SEC Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(e) - Subparagraph 53(1)(e)(iv) subscription for units of an underwater LP represented a contribution of capital
Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(a) subscription for units of an underwater LP represented an acquisition whose deemed cost was nil
8 October 2010 Roundtable, 2010-0373721C6 F - Divulgation volontaire Income Tax Act - Section 220 - Subsection 220(3.1) repeal of 38% rule (re tax rate on repatriated funds) in December 2008
8 October 2010 Roundtable, 2010-0373681C6 F - Production d'une Déclaration T3 Income Tax Regulations - Regulation 204 - Subsection 204(1) no obligation to file T3 where only property is non-income generating s. 75(2) property
Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(c) no penalty for failure to file T3 return
8 October 2010 Roundtable, 2010-0373551C6 F - Transfert entre conjoints et dette assumée Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) whether debt obligation incurred on co-owner’s assumption of other co-owner’s mortgage obligation requires an assessment of the before and after situation