We have translated 8 more CRA severed letters

21 February 2022 - 10:31pm
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We have published a further 8 translations of CRA interpretation released in June, 2005. Their descriptors and links appear below.

These are additions to our set of 1,932 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 2/3 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
2005-06-17 9 June 2005 Internal T.I. 2004-0105421I7 F - Déductibilité des frais juridiques et d'intérêts Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Damages legal fees to defend against claim for unpaid construction fees on building addition were on capital account
Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A legal fees to defend against claim for unpaid construction fees on building addition were not a capital cost addition
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(ii) interest paid pursuant to a judgment requiring payment of construction fees would be deductible but for s. 18(3.1)
Income Tax Act - Section 18 - Subsection 18(3.1) interest paid pursuant to a judgment requiring payment of construction fees would be capitalized to the construction costs to the extent of accrual during construction period
2005-06-10 11 May 2005 Roundtable, 2005-0127081C6 F - États financiers - Impôt de la Partie I.3 Income Tax Act - Section 181 - Subsection 181(3) GAAP refers to Canadian GAAP
9 June 2005 External T.I. 2004-0092001E5 F - Droits indivis dans les actions Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share undivided interests in SBC shares on s. 98(3) winding up could qualify as shares of QSBC shares
Income Tax Act - Section 248 - Subsection 248(1) - Share undivided interests in QSBC shares qualify as shares
24 May 2005 External T.I. 2005-0121291E5 F - Processing in Canada of ore Income Tax Regulations - Regulation 1204 - Subsection 1204(1) - Paragraph 1204(1)(b) - Subparagraph 1204(1)(b)(iii) - Clause Subparagraph 1204(1)(b)(iii)(A) second crushing of nickel ore at the surface generated gross resource profits
Income Tax Regulations - Schedules - Schedule II - Class 10 - Paragraph 10(k) mobile plant of subcontractor used at mine surface level to further crush ore before its transport qualified under 10(k)
Income Tax Act - Section 125.1 - Subsection 125.1(3) - Manufacturing or Processing - Paragraph (f) - Subparagraph (f)(i) second crushing of nickel ore at the surface is excluded processing
19 May 2005 External T.I. 2005-0113681E5 F - Dédommagement pour congédiement injustifié Income Tax Act - Section 5 - Subsection 5(1) court-ordered reinstatement order gives rise to employment income
11 May 2005 Roundtable, 2005-0118691C6 F - Certificat américain d'actions étrangères Income Tax Act - Section 181.2 - Subsection 181.2(4) - Paragraph 181.2(4)(a) ADR holder holds shares if such holder has all the attributes of ownership of the shares
31 May 2005 External T.I. 2005-0122641E5 F - Intérêts courus Income Tax Regulations - Regulation 7000 - Subsection 7000(2) - Paragraph 7000(2)(c.1) Reg. 7000(2)(c.1) applied on December 31 of each year to investment contract issued on January 1
Income Tax Act - Section 12 - Subsection 12(11) - Anniversary Day anniversary day for an investment contract issued on January 1 is December 31
11 May 2005 Roundtable, 2005-0118731C6 F - Contrat avec une société d'affacturage Income Tax Act - Section 181.2 - Subsection 181.2(3) - Paragraph 181.2(3)(f) characterization as “loans and advances” and “all other indebtedness” based on legal character