We have translated 10 more CRA interpretations
10 August 2021 - 1:54am
Email this ContentWe have published a further 10 translations of CRA interpretation released in June and May, 2007. Their descriptors and links appear below.
These are additions to our set of 1,662 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 14 ¼ years of releases of such items 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 |
|---|---|---|---|
| 2007-06-15 | 29 May 2007 Internal T.I. 2006-0217401I7 F - 110(1)d): Moment de la conclusion de la convention | Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d) - Subparagraph 110(1)(d)(ii) - Clause 110(1)(d)(ii)(A) | where options previously granted were not exercisable until an employer “Exercise Notice,” the stock option agreement was made at such notice time |
| Income Tax Act - Section 7 - Subsection 7(5) | not giving exercise notice to employees who are not shareholders (so that they cannot exercise their options) may engage s. 7(5) | ||
| 2007-06-08 | 30 May 2007 External T.I. 2006-0218101E5 F - Interaction entre 125.4(1) et 256(1.2)c) | Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(c) | s. 256(1.2)(c) does not affect the determination of de facto control |
| Income Tax Regulations - Regulation 1106 - Subsection 1106(2) | s. 256(1.2)(c) does not inform the definition of prescribed taxable Canadian corporation | ||
| 28 May 2007 External T.I. 2007-0219801E5 F - Paiement de soutien aux enfants | Income Tax Act - Section 74.1 - Subsection 74.1(2) | child assistance payment is transferred to a minor child is subject to s. 74.1(2) attribution | |
| 4 June 2007 Internal T.I. 2007-0229251I7 F - Montants reçus pour aide personnelle à domicile | Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | no income to parental caregiver in situations similar to Pellerin | |
| 9 May 2007 External T.I. 2006-0189931E5 F - Renonciation à une fiducie par un conjoint | Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | renunciation of interest in spousal trust not a disposition to the family beneficiaries | |
| Income Tax Act - Section 248 - Subsection 248(1) - Disposition | extinguishment of trust interests on their renunciation is a disposition of the renounced interest, but resulting variation of trust to accelerate distribution entitlements is not | ||
| Income Tax Act - 101-110 - Section 104 - Subsection 104(4) - Paragraph 104(4)(a) | variation of spousal trust, following renunciation by spouse, to accelerate distribution entitlement of residuary beneficiaries would not engage s. 104(4) until distribution | ||
| Income Tax Act - Section 70 - Subsection 70(6) | variation of spousal trust, following renunciation by spouse, to accelerate distribution entitlement of residuary beneficiaries would not deny s. 70(6) rollover | ||
| 5 June 2007 Internal T.I. 2007-0237291I7 F - Disposition d'une police d'assurance-vie | Income Tax Act - Section 148 - Subsection 148(7) | s. 148(7) applicable to gift of policies by partners to a limited partnership | |
| 30 May 2007 External T.I. 2006-0200271E5 F - Bien agricole et résidence principale | Income Tax Act - Section 40 - Subsection 40(4) | s. 45(3) election did not extend time that farm house was a principal residence, once the occupant went to nursing home | |
| Income Tax Act - Section 45 - Subsection 45(3) | no change of use when occupant of residence moved into a nursing home | ||
| Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1.3) - Paragraph 110.6(1.3)(c) | principally references over 50% of use | ||
| 11 May 2007 External T.I. 2006-0214351E5 F - Transfert d'un droit de propriété | Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(b) | where duplex co-owned by husband and wife, the one unit occupied by them can be designated as a principal residence – but this changes when daughter moves into the 2nd unit | |
| Income Tax Act - Section 248 - Subsection 248(1) - Property | an occupied unit in a co-owned duplex can be designated as a principal residence | ||
| 2007-06-01 | 24 May 2007 External T.I. 2006-0209081E5 F - Withholding Source Deductions - Trustee Fees | Income Tax Act - Section 248 - Subsection 248(1) - Office | fees if trustees of REIT based partly on the number of meetings they attended were from an office |
| Income Tax Regulations - Regulation 100 - Subsection 100(1) - Remuneration | fees received by REIT trustees including per-meeting fees were salary and wages subject to source deductions and T4 reporting | ||
| 2007-05-25 | 22 May 2007 External T.I. 2007-0228611E5 F - Crédit pour la création d'emplois pour apprentis | Income Tax Act - Section 127 - Subsection 127(9) - Eligible Apprentice | year means 12 months/”contract” for apprentice can be the collective agreement |