We have published 11 more translations of CRA interpretations

22 November 2021 - 10:59pm
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We have published a translation of a CRA interpretation released last week and a further 10 translations of CRA interpretation released in June and May, 2006. Their descriptors and links appear below.

These are additions to our set of 1,817 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 15 ½ 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
2021-11-17 7 July 2021 External T.I. 2020-0848251E5 F - Donation and CEWS qualifying revenue Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Revenue - Paragraph (c) gifts received by a registered charity are qualifying revenue
2006-06-02 29 May 2006 External T.I. 2005-0131701E5 F - Durée de l'exercice d'une société Income Tax Act - Section 249.1 - Subsection 249.1(3) s. 249(3) did not preclude a 53 week fiscal period covering 3 calendar years
9 May 2006 Internal T.I. 2006-0175551I7 F - Traitement fiscal d'un montant forfaitaire Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(a) - Subparagraph 39(1)(a)(iii) lump sum received in settlement of entitlement to future disability benefits was non-taxable s. 39(1)(a)(iii) receipt
Income Tax Act - Section 6 - Subsection 6(15) forgiveness of rehabilitation loan was taxable
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) lump sum received in settlement of entitlement to future disability benefits was not taxable under s. 6(1)(f), as was forgiveness of obligation to repay disability overpayments
9 May 2006 Internal T.I. 2006-0176371I7 F - Bourses d'études ou d'entretien Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) payments (made by application against student loans) were “given to students who need financial assistance to continue their education” and, thus, were bursaries
General Concepts - Payment & Receipt bursaries “received” by students even though required to be applied directly to their loans
12 May 2006 Internal T.I. 2006-0184781I7 F - Montant forfaitaire reçu en vertu de 56(1)v) Income Tax Act - 101-110 - Section 110.2 - Subsection 110.2(1) - Qualifying Amount lump sum workers’ compensation payments were not qualifying amounts
Income Tax Act - Section 122.5 - Subsection 122.5(1) - Adjusted Income deductibility of s. 56(1)(v) inclusions under s. 110(1)(f) did not detract from inclusion in adjusted income
Income Tax Act - Section 122.6 - Adjusted Income lump sum workers' compensation payments were deductible under s. 110(1)(f), but not deductible from adjusted income
3 May 2006 Internal T.I. 2005-0133341I7 F - Cours normal des activités de l'entreprise Income Tax Act - Section 112 - Subsection 112(2.1) s. 112(1) applies to dividends received through partnership/whether venture capital firm received such dividends in ordinary course turned on similarity of this with its other investments
2006-05-26 4 May 2006 Roundtable, 2005-0161541C6 F - Placements admissibles - dépôts Income Tax Act - Section 204 - Qualified Investment - Paragraph (b) GIC or term deposit is a similar obligation
Income Tax Act - Section 204 - Qualified Investment - Paragraph (f) GIC could qualify under para. (b) or (f)
Income Tax Act - Section 204 - Qualified Investment - Paragraph (a) not a qualifying deposit if payable outside Canada or in foreign currency
9 May 2006 External T.I. 2005-0161941E5 F - REER: Legs à une fiducie exclusive au conjoint Income Tax Act - Section 146 - Subsection 146(8.1) election could be made regarding encroachment of capital to beneficiary of spousal trust
10 May 2006 External T.I. 2005-0162591E5 F - Renonciation à une succession: REER Income Tax Act - Section 146 - Subsection 146(8.1) renunciation by two children for the benefit of the other heir did not give rise to a transfer as a consequence of death
Income Tax Act - Section 248 - Subsection 248(8) - Paragraph 248(8)(b) renunciation by two children for the benefit of the other heir would not qualify
11 May 2006 Internal T.I. 2006-0178781I7 F - Résidence des membres du clergé Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(c) pastoral worker not entitled to deduction
18 May 2006 Internal T.I. 2006-0182321I7 F - Déduction des intérêts Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) refinancing dividend-payment notes with interest-bearing shareholder loans did not cure the interest-deductibility problem