6 more translated CRA interpretations are available

5 May 2020 - 12:00am
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We have published a translation of a CRA interpretation released last week and a further 5 translations of CRA interpretations released in October and September, 2010. Their descriptors and links appear below.

These are additions to our set of 1,164 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 9 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 May.

Bundle Date Translated severed letter Summaries under Summary descriptor
2020-04-29 9 March 2020 External T.I. 2013-0490301E5 F - Société exploitant une EPSP Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(p) - Subparagraph 18(1)(p)(ii) PSB can deduct for auto leasing costs or loan interest expense to extent of benefit conferred on the individual qua employee rather than shareholder – but no CCA deduction (other than under s. 18(1)(p)(iii))
2010-10-15 12 August 2010 External T.I. 2010-0370551E5 F - Tuck Under Transaction - Tremblay Decision Income Tax Act - Section 84 - Subsection 84(2) despite Tremblay, CRA may challenge tuck-under transactions that do more than extract safe income
12 August 2010 Internal T.I. 2010-0356781I7 F - Allocation de retraite, indemnité 2091 C.c.Q. Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance compensation paid in lieu of notice generally is a retiring allowance
22 September 2010 External T.I. 2010-0373041E5 F - Résidence principale Income Tax Act - Section 54 - Principal Residence - Paragraph (e) holding land within ½ hectare area under separate title does not preclude exemption applying to such adjacent land
14 June 2010 Internal T.I. 2010-0366611I7 F - Determination of CCPC Status Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) sole beneficiary of a trust did not have a s. 251(5)(b) right to trust shares
General Concepts - Agency application of Kinguk Trawl test of agency
Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation - Paragraph (b) agreement was not a USA since it did not contain an outright transfer of the powers of the directors to the shareholders
Income Tax Act - Section 256 - Subsection 256(5.1) non-resident shareholder with 60%+ economic interest, extensive veto rights and responsibility for future funding of R&D work had de facto control
2010-09-17 7 September 2010 External T.I. 2009-0340861E5 F - Déduction pour amortissement - Catégorie 52 Income Tax Regulations - Regulation 1104 - Subsection 1104(2) - General-Purpose Electronic Data Processing Equipment not "general-purpose electronic data processing equipment" if no ability of user to alter the embedded program