We have translated 6 more CRA Interpretations

7 September 2020 - 9:13pm
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We have published a further 6 translations of CRA interpretations released in February, 2010. Their descriptors and links appear below.

These are additions to our set of 1,262 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 10 1/2 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 September.

Bundle Date Translated severed letter Summaries under Summary descriptor
2010-02-26 29 January 2010 Internal T.I. 2009-0339541I7 F - Inclusion au revenu et provision Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) advance fees for futures goods-handling services included in income under s. 12(1)(a) rather than s. 9
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) reserve available for future goods handling services to be performed
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense no deduction from prepaid fees of estimated cost of performance
16 February 2010 External T.I. 2010-0354801E5 F - CIRD - construction d'un logement General Concepts - Ownership individual is considered to become owner of home in construction when it becomes habitable
Income Tax Act - Section 118.04 - Subsection 118.04(1) - Qualifying Renovation credit dependent on timing of renovation expenditures and when moved into home
18 March 2008 External T.I. 2008-0265861E5 F - Programme d'aide financière d'urgence ("PAFU") Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) s. 56(1)(u) applied to emergency assistance not based on an income test
Statutory Interpretation - French and English Version English version of s. 56(1)(u), as the broader of the two, was to be preferred
Income Tax Act - Section 153 - Subsection 153(1) no source deductions from social assistance payments
2 February 2010 Internal T.I. 2009-0345741I7 F - Programme d'aide financière d'urgence ("PAFU") Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) social assistance paid without a means, needs or income test was not income to recipient
Income Tax Regulations - Regulation 233 - Subsection 233(2) - Paragraph 233(2)(g) lump sum emergency assistance under Quebec program would not be required to be included in income because no information slip required
16 February 2010 External T.I. 2009-0322751E5 F - Traitement fiscal des indemnités reçues Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) prejudgment interest included in class action award was tax free
2010-02-19 9 February 2010 External T.I. 2009-0316561E5 F - Biens en immobilisations-RS&DE Income Tax Act - Section 127 - Subsection 127(9) - First Term Shared-Use Equipment expected use throughout expected useful life is considered
Income Tax Regulations - Regulation 2900 - Subsection 2900(11) requirement during establishment phase to be used primarily during useful life for SR&ED