We have translated 6 more CRA Interpretations

16 November 2020 - 10:45pm
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We have published 6 further translations of CRA interpretation released in November, 2009. Their descriptors and links appear below.

These are additions to our set of 1,321 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 11 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
2009-11-13 4 November 2009 External T.I. 2009-0337451E5 F - Fractionnement de revenu de pension Income Tax Act - Section 118 - Subsection 118(7) - Qualified Pension Income RPP pension, but not annuity paid out of his RRSP, was eligible as qualified pension income of pensioner for s. 60.03 splitting
Income Tax Act - Section 60.03 - Subsection 60.03(1) - Split-Pension Amount RRSP annuity not eligible for splitting
2 November 2009 External T.I. 2009-0345491E5 F - Crédit d'impôt pour frais médicaux Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(l.2) lowering of windows with sliding openings could potentially qualify
2 November 2009 External T.I. 2009-0317541E5 F - Transfer to Corporations Owned by Brothers Income Tax Act - Section 55 - Subsection 55(5) - Paragraph 55(5)(e) - Subparagraph 55(5)(e)(ii) s. 55(3)(a) exemption turned on s. 55(5)(e)(ii)
Income Tax Act - Section 55 - Subsection 55(4) use of special voting shares by father questioned where most of the economic interest in the split-up business goes to the children
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest on debt assumed by Holdco to acquire non-dividend-bearing prefs of Opco was non-deductible even though commons also acquired – but amalgamation cured
2009-11-06 2 November 2009 External T.I. 2009-0317681E5 F - Crédit d'impôt pour la rénovation domiciliaire Income Tax Act - Section 118.04 - Subsection 118.04(1) - Qualifying Expenditure qualifying expenditures can include fees of designer
14 October 2009 External T.I. 2009-0324331E5 F - Placement admissible, part de coopérative Income Tax Regulations - Regulation 4901 - Subsection 4901(2) - Qualifying Share share that is not entitled to receive an allocation in proportion to patronage in respect of consumer goods or services could be a qualified investment
14 October 2009 External T.I. 2009-0325101E5 F - Placement admissible, part de coopérative Income Tax Regulations - Regulation 4900 - Subsection 4900(14) - Paragraph 4900(14)(a) - Subparagraph 4900(14)(a)(iii) both Reg. 4901(2)(a) and (b) need not be satisfied