We have translated 5 more CRA Interpretations

30 November 2020 - 10:52pm
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We have published 5 further translations of CRA interpretation released in October and September, 2009. Their descriptors and links appear below.

These are additions to our set of 1,331 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 11 ¼ 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
2009-10-16 30 September 2009 External T.I. 2009-0317641E5 F - Attribution de revenu Income Tax Act - Section 75 - Subsection 75(2) issuance of shares at FMV is not a transfer of property to which s. 75(2) can apply
Income Tax Act - 101-110 - Section 104 - Subsection 104(6) - Paragraph 104(6)(b) discretionary trust could distribute, and deduct under s. 104(6), a dividend received by it to a corporate beneficiary incorporated after the dividend’s receipt
2009-10-09 30 September 2009 External T.I. 2009-0340061E5 F - FERR au profit de l'époux ou du conjoint de fait Income Tax Act - Section 146 - Subsection 146(1) - Spousal or Common-Law Partner Plan a RRIF receiving a transfer from a spousal or common-law partner RRSP is rendered a spousal or common-law partner plan
2009-10-02 16 September 2009 External T.I. 2008-0295951E5 F - Article XVI de la Convention Canada-É.U Treaties - Income Tax Conventions - Article 16 $15,000 gross receipts exclusion under Art. XVI(1) of US Convention is inapplicable where the income is earned by the artist’s corporation
2009-09-25 8 September 2009 External T.I. 2008-0299771E5 F - Gain on Disposition of Debt Income Tax Act - Section 43 - Subsection 43(1) partial repayment of low-ACB debt generates a capital gain
Income Tax Act - Section 9 - Computation of Profit partial repayment of low-cost debt generates business income if held on income account
17 September 2009 External T.I. 2009-0310251E5 F - Interaction between sections 89 and 55 Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (a) addition to CDA from redemption engaging s. 55(2) occurs at redemption time