We have translated 5 more CRA Interpretations
13 July 2020 - 11:39pm
Email this ContentWe have published a further 5 translations of CRA interpretations released in May, 2010. Their descriptors and links appear below.
These are additions to our set of 1,219 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 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 |
|---|---|---|---|
| 2010-05-28 | 19 May 2010 External T.I. 2009-0342651E5 F - Remboursement de dépenses et allocations | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | reimbursement for employment-related moving expenses, and reimbursement of accommodation and transportation where employee temporarily assigned away from normal home base, not taxable |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) | first $650 of allowance to cover moving costs not taxable | ||
| Income Tax Act - Section 6 - Subsection 6(23) | reimbursement of expenses to obtain a mortgage is included | ||
| 30 March 2010 Internal T.I. 2010-0354391I7 F - P.VI.1:Rachat à l'enchère hollandaise modifiée | Income Tax Act - Section 248 - Subsection 248(1) - Short-Term Preferred Share - Paragraph (a) - Subparagraph (a)(i) | deemed dividends on redemption of common shares tendered under modified Dutch auction came within (a)(i) and (e)(i) FMV exception | |
| General Concepts - Fair Market Value - Shares | purchase price established under modified Dutch auction represented the tendered shares’ FMV | ||
| 2010-05-21 | 13 May 2010 External T.I. 2009-0328741E5 F - Régime "à prix coûtant majoré" | Income Tax Act - Section 248 - Subsection 248(1) - Private Health Services Plan | satisfaction of “reasonable risk” condition in IT-339R2 for cost-plus plan |
| 27 April 2010 Internal T.I. 2009-0335761I7 F - REÉR et revenu d'un Indien | Other Legislation/Constitution - Federal - Indian Act - Section 87 | s. 87 exemption did not apply to blatant RPP/RRSP stripping arrangement | |
| Income Tax Act - Section 146 - Subsection 146(10) | ss. 146(9) and (10) applicable to RRSP purchase of Coop units at undervalue and loan by Coop to annuitant | ||
| 2010-05-14 | 13 May 2010 External T.I. 2009-0343971E5 F - Société de services pour les professionnels | Income Tax Act - Section 67 | deductibility of management fees paid by professional practice to services corporation |