We have translated 5 more CRA Interpretations

14 September 2020 - 11:39pm
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We have published a further 5 translations of CRA interpretations released in February, 2010. Their descriptors and links appear below.

These are additions to our set of 1,267 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.

Bundle Date Translated severed letter Summaries under Summary descriptor
2010-02-19 25 January 2010 Internal T.I. 2009-0345501I7 F - Allocations pour frais de déplacement Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(b) - Subparagraph 6(6)(b)(i) potential application to track maintenance employees
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii.1) absence of any services rendered during travel indicates the travel was not in the course of employment
3 November 2008 External T.I. 2008-0278431E5 F - Déménagement hors Canada du siège soc. de société Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(ii) OECD Commentary informs allocation of sales through non-resident office to Cdn manufacturing operation
Income Tax Act - Section 250 - Subsection 250(5) central management and control test overridden
Income Tax Act - Section 127 - Subsection 127(9) - Investment Tax Credit - Paragraph (a.1) ITC potentially available to a non-resident corporation carrying on business in Canada
Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(b) s. 4(1)(b) requires allocation between Canada and another country on basis of relative profit contribution
5 February 2010 Internal T.I. 2009-0348921I7 F - Application d'un jugement de la CCI Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) Dupuis not being followed
8 February 2010 Internal T.I. 2009-0352721I7 F - Allocations pour frais de repas Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(vii) meaning of regular place of employment
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) no taxable benefit from $17 meal allowance paid where 2 or more hours of occasional contiguous overtime
8 February 2010 External T.I. 2009-0337691E5 F - Assurance frais-généraux Income Tax Act - Section 9 - Nature of Income excess of overhead disability insurance received over overhead expense actually incurred was s. 9 income