We have translated 7 more CRA Interpretations

We have published a translation of a CRA interpretation released last week, and a further 6 translations of CRA interpretation released in April and March, 2009. Their descriptors and links appear below.

These are additions to our set of 1,392 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 11 3/4 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
2021-02-10 29 September 2020 External T.I. 2018-0757501E5 F - Crédit pour intérêts sur les prêts étudiants Income Tax Act - Section 118.62 capitalization of interest on a novation would constitute its payment – but novated loan would be a new non-student loan
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(d) capitalization of unpaid interest by way of novation constituted its payment
General Concepts - Payment & Receipt capitalization of interest on a novation under Quebec law would constitute its payment
2009-04-10 27 March 2009 Internal T.I. 2009-0308111I7 F - Crédit d'impôt pour enfant Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b.1) s. 118(9.1) applies to death of dependant child, but not to parent
2009-04-03 23 March 2009 External T.I. 2008-0293131E5 F - Prestations reçues par une succession Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) amounts received by estate in settlement of deceased’s action for unpaid employment-termination disability were taxable
Income Tax Act - Section 70 - Subsection 70(2) amounts received by estate in settlement of deceased’s action for unpaid disability were rights and things
Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit survivor benefit in settlement of rights under a wage loss replacement plan could be a death benefit
2009-03-27 19 March 2009 Internal T.I. 2009-0306971I7 F - 6801(d): Traitement fiscal pour l'employé Income Tax Regulations - Regulation 6801 - Paragraph 6801(d) DSU cash-out amount is employment income
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) appreciation in DSUs is not a capital gain
18 March 2009 External T.I. 2009-0309211E5 F - Crédits d'impôt personnels Income Tax Act - Section 118.92 ordering of tuition, then medical expense, then student loan credits
Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(d) satisfaction of clothing needs of institutionalized adult child would be sufficient to engage the credit
Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) parent separated for part of year could claim the wholly dependent person credit only if he did not deduct support
5 March 2009 External T.I. 2008-0279241E5 F - Prestation consécutive au décès Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit benefit paid on union member’s death could not be a death benefit (no employer-employee relationship
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(j) amount paid to union member could be treated as a refund of union dues with the balance taxable under s. 6(1)(j)
Income Tax Act - Section 70 - Subsection 70(2) lump sum paid to a union member on death could be in satisfaction of a right or thing
2009-03-20 11 March 2009 External T.I. 2009-0306601E5 F - Remboursement de cotisations syndicales Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(j) amounts received from a union that are not a reimbursement of union dues generally are exempt
Income Tax Act - Section 3 - Paragraph 3(a) Fries applied re exempt distributions from a union