We have translated 11 more CRA severed letters
11 April 2022 - 11:11pm
Email this ContentWe have published translations of 3 CRA severed letters released last week and a further 8 translations of CRA interpretation released in March and February, 2005. Their descriptors and links appear below.
These are additions to our set of 1,996 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 17 years of releases of such items by the Directorate. These translations are subject to our paywall (applicable after the 5th of each month).
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2022-04-06 | 2017 Ruling 2017-0696791R3 F - Reduction of PUC/capital | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | interest on money borrowed by Subco for distribution of share-capital account to its parent is deductible if the Subco property continues generating business incomeAmended and supplemented by 2017-0696792R3 F |
| Income Tax Act - Section 51 - Subsection 51(1) | s. 51(1) will apply where convertible note, that was issued as boot, will be converted to sharesAmended and supplemented by 2017-0696792R3 F | ||
| 2019 Ruling 2017-0696792R3 F - Internal reorganization | Amending and supplementing 2017-0696791R3 F | ||
| 7 January 2022 External T.I. 2020-0866751E5 F - CEWS and government financial assistance | Income Tax Act - Section 125.7 - Subsection 125.7(4) | government assistance based partly on payroll levels would not be qualifying revenue if normal accounting practice would be to contra payroll expense | |
| Income Tax Act - Section 125.7 - Subsection 125.7(1) - Qualifying Revenue | government assistance that under normal accounting practice was applied to reduce recorded expenses would not be qualifiying revenue | ||
| 2005-03-11 | 3 March 2005 External T.I. 2004-0096371E5 F - Revenu tiré d'un emploi et 110(1)f)(iii) | Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(f) - Subparagraph 110(1)(f)(iii) | no special tests under s. 110(1)(f)(iii) for determining whether the individual is self-employed |
| 2005-03-04 | 7 February 2005 External T.I. 2004-0101421E5 F - Subsection 111(5.1) | General Concepts - Fair Market Value - Other | depreciable assets’ value inferred from the share purchase price |
| Income Tax Act - Section 111 - Subsection 111(5.1) | FMV of assets should be established on a push-down basis from the share purchase price, but can be allocated based on an appraisal | ||
| 28 February 2005 Internal T.I. 2004-0103991I7 F - Remboursement de frais de scolarité | Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) | agreement of employer to pay tuition would have been taxable under s. 6(3) if a benefit | |
| Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | payment of tuition fees conditional on a return to extended employment was not a taxable benefit | ||
| 28 February 2005 External T.I. 2004-0104121E5 F - Détermination du statut de résidence | Income Tax Regulations - Regulation 2607 | individual working in Ontario but visiting Quebec family home twice monthly likely was resident in Quebec | |
| 7 February 2005 External T.I. 2005-0111431E5 F - Death of a Taxpayer - Deduction of CCDE | Income Tax Act - Section 66.2 - Subsection 66.2(2) | CCDE balance cannot be deducted in terminal return or by estate | |
| Income Tax Act - Section 70 - Subsection 70(5.2) | no s. 70(5.2) deduction where CCDE balance arose “through” a partnership | ||
| 23 February 2005 External T.I. 2004-0093921E5 F - Déménagement d'un employé-Paiement de frais | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | payment of house-hunting fee for new hire was non-taxable | |
| 2005-02-25 | 17 February 2005 External T.I. 2004-0091811E5 F - Exemption pour résidence principale | Income Tax Act - Section 54 - Principal Residence | separate municipal addresses not determinative that basement occupied by son and ground floor occupied by mother were two housing units |
| Income Tax Act - Section 54 - Principal Residence - Paragraph (a) | where residence held by son and mother in equal co-ownership is 2 units each occupied separately, each could technically access the exemption for only a ¼ interest | ||
| 17 February 2005 External T.I. 2004-0104331E5 F - Indemnisation et autres paiements | Income Tax Act - Section 5 - Subsection 5(1) | portions of settlement payment that compensated for lost vacation credits and reimbursed for psychotherapy and medication costs were taxable under s. 5(1) |