We have translated 10 more CRA Interpretations
8 March 2021 - 10:34pm
Email this ContentWe have published a translation of a CRA interpretation released last week, and a further 9 translations of CRA interpretation released in December and November, 2008. Their descriptors and links appear below.
These are additions to our set of 1,419 full-text translations of French-language Roundtable items and Technical Interpretations of the Income Tax Rulings Directorate, which covers all of the last 12 1/3 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 |
|---|---|---|---|
| 2021-03-03 | 2 September 2020 External T.I. 2018-0738271E5 F - Taxable capital gain designation | Income Tax Act - 101-110 - Section 104 - Subsection 104(21.2) | the QSBC character of capital gains can be flowed out through 2 levels of personal trusts |
| 2008-12-12 | 2 December 2008 Internal T.I. 2008-0270981I7 F - Entreprise de prestation de services personnels | Income Tax Act - Section 246 - Subsection 246(1) | s. 246(1) could apply re individual’s personal use of residence held in partnership mostly owned by his Holdco |
| 2008-11-28 | 21 November 2008 External T.I. 2008-0279231E5 F - Revenu de commission | Income Tax Act - Section 9 - Nature of Income | CRA exempting of non-substantial commissions received by brokers for sales to themselves of life insurance or critical illness policies does not extend to other financial products |
| 17 November 2008 Internal T.I. 2008-0293121I7 F - Crédit d'impôt pour déficience mentale ou physique | Income Tax Act - Section 118.3 - Subsection 118.3(1) - Paragraph 118.3(1)(c) | nursing home exclusion could extend to credit claimed under s. 118.2(2)(e) if the individual does not receive highly specialized care | |
| 25 November 2008 External T.I. 2008-0297631E5 F - Déductibilité des intérêts dans une compagnie | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest-free loan made by Opco to fund acquisition of its shares did not satisfy any indirect use test | |
| 17 November 2008 Internal T.I. 2008-0299621I7 F - Allocation de retraite | Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | amounts received for lost wages, and pain and suffering, under ss. 53(2)(c) and (e), respectively, of the Canadian Human Rights Act were taxable, and non-taxable | |
| 2008-11-21 | 10 November 2008 External T.I. 2007-0237551E5 F - Vente à tempérament | Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A | acquisition and disposition under instalment sale when purchaser obtains possession, the right of use and to collect the fruits |
| 6 November 2008 Internal T.I. 2008-0292561I7 F - DAPE multiple | Income Tax Act - Section 125 - Subsection 125(7) - Personal Services Business | PSBs where 4 brothers and an executive provided all the management services to a jointly owned construction company through their respective managementcos | |
| Income Tax Act - Section 256 - Subsection 256(2.1) | application of s. 256(2.1) to SBD multiplication where 4 brothers provided their management services to Opco through their respective managementcos | ||
| 12 November 2008 External T.I. 2008-0295731E5 F - Supplément remboursable pour frais médicaux | Income Tax Act - Section 96 - Subsection 96(1) - Paragraph 96(1)(f) | statutory reference to sources of income from businesses did not require netting business loss from 1st partnership against business income from 2nd partnership | |
| Income Tax Act - Section 122.51 - Subsection 122.51(1) - Eligible Individual - Paragraph (c) - Subparagraph (c))ii) | reference to sources of income from business did not require netting partnership business loss against business income from 2nd partnership | ||
| 2008-11-07 | 3 November 2008 External T.I. 2008-0289701E5 F - Paiement fait à la succession d'un employé | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) | lump sum paid by employer to estate of employee, compensating for insurance proceeds that the estate could have claimed, was non-taxable under surrogatum principle |