We have translated 5 more CRA Interpretations
24 August 2020 - 11:58pm
Email this ContentWe have published a further 5 translations of CRA interpretations released in March, 2010. Their descriptors and links appear below.
These are additions to our set of 1,251 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 1/3 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 |
|---|---|---|---|
| 2010-03-26 | 9 February 2010 Internal T.I. 2009-0333571I7 F - Paragraphe 7(1.5) - contrepartie reçue | Income Tax Act - Section 7 - Subsection 7(1.5) | s. 7(1.5) rollover where employees exchanged specific s. 7(1.1) shares for shares of grandparent, even though they also received cash and PUC distribution |
| Income Tax Act - Section 53 - Subsection 53(1) - Paragraph 53(1)(j) | ACB increased by s. 7(1) benefit that had not yet been triggered due to s. 7(1.5) rollover | ||
| Income Tax Act - Section 116 - Subsection 116(1) | s. 116 certificate required even for shares disposed of under s. 7(1.5) rollover | ||
| Income Tax Act - Section 7 - Subsection 7(1.4) | non-resident ex-employees will be required to recognize s. 7 benefit deferred by s. 7(1.5) when they dispose of the shares acquired in exchange | ||
| 15 March 2010 Internal T.I. 2009-0352731I7 F - Remboursement de rémunération | Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(n) | deduction for repayment of amounts received during deferred salary leave period following failure to return to work | |
| 2010-03-19 | 11 March 2010 External T.I. 2009-0345481E5 F - Allocations versées administrateurs bénévoles | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) | allowances and travel reimbursements paid by NPO to volunteer directors were non-taxable |
| Income Tax Act - Section 248 - Subsection 248(1) - Office | definition of a “volunteer” (who is excluded from the holder of an “office”) | ||
| 1 March 2010 Internal T.I. 2009-0346951I7 F - Article XVI-Établissement stable-Province | Income Tax Regulations - Regulation 400 - Subsection 400(2) | being on concert tour in Canada did not render the various arenas fixed places of business, given lack of “regularity and recurrence” | |
| Income Tax Regulations - Regulation 400 - Subsection 400(2) - Paragraph 400(2)(e) | using massive stage equipment for Canadian concerts did not result in deemed PEs given that at each venue under 30 days and in Canada under 90 days | ||
| Treaties - Income Tax Conventions - Article 16 | Art. XVI of US Convention applicable irrespective of whether a PE | ||
| 2010-03-12 | 4 March 2010 External T.I. 2009-0343851E5 F - Remboursement des cotisations à un club | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | reimbursements of employee fitness facility fees are considered principally for employees’ benefit if membership merely improves their performance through increased health |