We have published 11 more translations of CRA interpretations
14 December 2021 - 12:40am
Email this ContentWe have published a translation of a ruling released by CRA last week and a further 10 translations of CRA interpretation released in March and February, 2006. Their descriptors and links appear below.
These are additions to our set of 1,849 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 ¾ 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 |
|---|---|---|---|
| 2021-12-08 | 2020 Ruling 2020-0844081R3 F - Rollout of property to beneficiaries | Income Tax Act - 101-110 - Section 107 - Subsection 107(2) | s. 107(2) applicable to distribution of trust’s shares to beneficiaries followed by an immediate s. 85(1) roll into holdco controlled by father |
| Income Tax Act - 101-110 - Section 104 - Subsection 104(4) | a trust should distribute shares of an Amalco whose predecessor had received shares as beneficiary of another discretionary family trust before the latter’s 21-year anniversary | ||
| 2006-03-17 | 3 March 2006 Internal T.I. 2005-0151871I7 F - Déduction des intérêts | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) | notes issued to replace notes issued to pay dividends did not qualify as refinancing borrowed money under s. 20(3) or as being for the acquisition of property per s. 20(1)(c)(ii)subsequently confirmed in 2006-0182321I7 F |
| 13 February 2006 External T.I. 2005-0153561E5 F - Aggregate Investment Income | Income Tax Act - Section 129 - Subsection 129(4) - Aggregate Investment Income - Paragraph (b) - Subparagraph (b)(iv) | rental income allocated by a unit trust could be active business income | |
| 2006-03-03 | 15 February 2006 External T.I. 2005-0126831E5 F - 120.4(1) - définition : montant exclu | Income Tax Act - Section 120.4 - Subsection 120.4(1) - Excluded Amount - Paragraph (a) | para. (a) exclusion does not apply to substituted property |
| Income Tax Act - Section 248 - Subsection 248(5) | phrase “substituted property” must be used to engage s. 248(5) | ||
| 1 February 2006 External T.I. 2005-0142411E5 F - Don entre vifs - bien agricole admissible | Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) | words of transfer not determinative as to whether there is a gift or sale for nominal consideration | |
| 17 February 2006 External T.I. 2005-0153931E5 F - Primes d'installation médecins | Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | signing bonuses to medical practitioners to establish in remote areas are taxable | |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | signing bonuses to medical practitioners to locate in remote areas are a taxable benefit | ||
| 2006-02-17 | 2 February 2006 External T.I. 2005-0152871E5 F - Crédit d'impôt pour emploi à l'étranger | Income Tax Act - Section 122.3 - Subsection 122.3(1) - Paragraph 122.3(1)(a) | partial funding under Reg. 3400 international development assistance program precludes credit |
| 7 February 2006 External T.I. 2005-0122381E5 F - Consequential assessment | Income Tax Act - Section 152 - Subsection 152(4.3) | taxpayer following a redetermination to allow a loss for Year 1 can carry that loss forward to a statute-barred year pursuant to s. 152(4.3) | |
| 2 February 2006 External T.I. 2005-0127351E5 F - Fiducie révocable -Prêt authentique | Income Tax Act - Section 75 - Subsection 75(2) | exception for bona fide loans/trustee may guarantee a loan | |
| 2006-02-10 | 2 February 2006 External T.I. 2005-0111911E5 F - Participation indivise dans un immeuble-fiducie | Income Tax Act - Section 70 - Subsection 70(5) | grant under will of usufruct and bare ownership to surviving spouse and children, respectively, resulted in a deemed s. 70(5) disposition to a testamentary trust |
| Income Tax Act - Section 54 - Principal Residence - Paragraph (c.1) | grant under will of usufruct in 2-unit property to surviving spouse constituted a disposition to a testamentary trust which could make the (c.1) designation for the home unit | ||
| 2 February 2006 External T.I. 2005-0152431E5 F - Utilization of non-capital losses | Income Tax Act - Section 69 - Subsection 69(11) | s. 69(11) would not apply where losses are applied against services income of Amalco | |
| Income Tax Act - Section 256 - Subsection 256(7) - Paragraph 256(7)(a) - Subparagraph 256(7)(a)(i) | s. 256(7)(a)(i) applicable where sister transfers Lossco to Profitco owned equally by her and three siblings |