We have translated 5 more CRA Interpretations

18 January 2021 - 10:25pm
Email this ContentEmail this Content

We have published a further 5 translations of CRA interpretation released in June 2009. Their descriptors and links appear below.

These are additions to our set of 1,368 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 11 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
2009-06-12 27 May 2009 Internal T.I. 2009-0320311I7 F - CELI - Notion d'avantage Income Tax Act - Section 207.01 - Subsection 207.01(1) - Advantage - Paragraph (b) - Subparagraph (b)(ii) accretion in common shares issued to employee's TFSA on an estate freeze was an advantage
3 June 2009 External T.I. 2009-0319551E5 F - Déductibilité des dépenses Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit test for identifying a business source
2009-06-05 26 May 2009 External T.I. 2009-0316841E5 F - Convention de retraite, crédit d'impôt étranger Income Tax Act - Section 126 - Subsection 126(1) no foreign tax credit can be claimed for non-business income tax paid on income of RCA trust
Income Tax Act - Section 207.5 - Subsection 207.5(1) - Refundable Tax - Paragraph (b) usual Pt. I deductions, including under ss. 20(11) and (12), can apply to computing income under para. (b)
27 May 2009 Internal T.I. 2009-0310751I7 F - Usufruit d'un immeuble avant 1991 Income Tax Act - Section 248 - Subsection 248(3) re a usufruct created prior to 1991, the usufructuary was considered to continue as the beneficial owner
Income Tax Act - Section 54 - Principal Residence usufructuary under usufruct created prior to 1991 was beneficial owner on his death in 2007 for principal residence exemption purposes
22 May 2009 Internal T.I. 2009-0312791I7 F - Transfert de biens entre un rentier et son REÉR Income Tax Act - Section 146 - Subsection 146(1) - Premium purchase of RRRSP property at cost is viewed as premium to the extent of excess over FMV
Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) an RRSP trust’s annuitant does not deal at arm’s length under s. 251(1)(c) with the RRSP