6 more translated CRA interpretations are available

10 February 2020 - 11:55pm
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We have published a translation of an interpretation that was released last week and a further 5 translations of CRA interpretations released in March, 2011. Their descriptors and links appear below.

These are additions to our set of 1,084 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 February.

Bundle Date Translated severed letter Summaries under Summary descriptor
2020-02-05 14 January 2020 Internal T.I. 2018-0785991I7 F - Subsection 86.1(2) Income Tax Act - Section 86.1 - Subsection 86.1(2) s. 86.1(2)(c)(i) references central management and control test/tracking shares satisfied s. 86.1(2)(a)
Income Tax Act - Section 248 - Subsection 248(1) - Common Share tracking shares were common shares
2011-03-04 8 October 2010 Roundtable, 2010-0373701C6 F - Affectation de paiement par l'ARC Income Tax Act - Section 157 - Subsection 157(1) final payments for year should be sent with remittance vouchers to reduce misapplications
8 October 2010 Roundtable, 2010-0373361C6 F - Gel successoral - société de personnes Income Tax Act - 101-110 - Section 103 - Subsection 103(1.1) s. 103(1.1) could apply to partnership estate freeze
8 October 2010 Roundtable, 2010-0373611C6 F - Certificat avant distribution Income Tax Act - Section 159 - Subsection 159(2) repayment of note to unsecured creditor was a distribution
Income Tax Act - Section 159 - Subsection 159(3) directors of corporate trustee generally are generally not liable under s. 159(3)
8 October 2010 Roundtable, 2010-0373481C6 F - Remboursement de commissions Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(f) required repayment of sales commission potentially deductible under s. 8(1)(f)
8 October 2010 Roundtable, 2010-0373261C6 F - Choix prévu au paragraphe 184(3) Income Tax Act - Section 184 - Subsection 184(3) permission to late-file a s. 184(3) after an objection has failed might be granted
Income Tax Act - Section 220 - Subsection 220(3.5) no policy to automatically waive penalty where late s. 184(3) election, following failed appeal, is granted