We have translated 8 more CRA interpretations

7 February 2022 - 11:07pm
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We have published a further 8 translations of CRA interpretation released in July, 2005. Their descriptors and links appear below.

These are additions to our set of 1,915 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 16 ½ years of releases of such items by the Directorate. These translations are subject to the usual (3 working weeks per month) paywall. You are currently in the “open” week for February.

Bundle Date Translated severed letter Summaries under Summary descriptor
2005-07-29 28 June 2005 Internal T.I. 2005-0115721I7 F - Entreprise de prestation de services personnels Income Tax Act - Section 125 - Subsection 125(7) - Personal Services Business high degree of control and integration with the business of a corporation established that the respective services providers had PSBs
21 June 2005 Internal T.I. 2005-0120341I7 F - Paragraphe 80(15). Income Tax Act - Section 80 - Subsection 80(15) s. 80(15) forgiven amount can be applied against NCLs or ACB that are unconnected to the partnership
22 June 2005 External T.I. 2005-0136941E5 F - Don par testament Income Tax Act - Section 152 - Subsection 152(4.2) the terminal return could be requested after the normal reassessment period to be reassessed to reflect a gift under the will
2005-07-22 13 July 2005 External T.I. 2005-0132631E5 F - Prestation fiscale canadienne pour enfants Income Tax Act - Section 122.61 - Subsection 122.61(1) Act does not preclude the sharing of the credit
2005-07-08 23 June 2005 Internal T.I. 2005-0118191I7 F - Améliorations faites à un séchoir à bois Income Tax Regulations - Schedules - Schedule II - Class 43 post-1992 alteration to equipment must be major in order to constitute a Class 43 addition
6 July 2005 External T.I. 2005-0123311E5 F - paiement à employé pour règlement d'un litige Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) amount received as compensation for tax on s. 7 benefit that was realized but never available to the employee was a s. 6(1)(a) benefit
Income Tax Act - Section 9 - Compensation Payments compensation for capital loss on stock option shares amount was taxed on capital account
24 June 2005 External T.I. 2005-0126251E5 F - Montants alloués pour personne handicapée Income Tax Act - Section 118 - Subsection 118(6) taxpayer could not claim the s. 118(1)(d) credit since she no longer was supporting her daughter
Income Tax Act - Section 118.3 - Subsection 118.3(2) parent could not take a transfer of the unused credit because she was no longer financially supporting her impaired daughter
5 July 2005 Internal T.I. 2005-0132671I7 F - Filing of Return - Corporation Being Wound Up Income Tax Act - Section 150 - Subsection 150(1) - Paragraph 150(1)(a) - Subparagraph 150(1)(a)(i) - Clause 150(1)(a)(i)(A) returns must be filed following winding-up until dissolution