We have translated 8 more CRA severed letters
7 November 2022 - 10:38pm
Email this ContentWe have published 2 translations of rulings released by CRA last week and a further 6 translations of CRA interpretations released in January of 2004. Their descriptors and links appear below.
These are additions to our set of 2,271 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 18 ¾ 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 |
|---|---|---|---|
| 2022-11-02 | 2022 Ruling 2022-0925601R3 F - Post-mortem Pipeline | Income Tax Act - Section 84 - Subsection 84(2) | pipeline accomplished through the Newco purchaser issuing 8 instalment notes to the estate as a PUC reduction |
| 2022-10-12 | 2021 Ruling 2021-0895071R3 F - Partnership Reorganization | Income Tax Act - Section 98 - Subsection 98(3) | conversion of a carry to a straight-up interest |
| Income Tax Act - Section 40 - Subsection 40(3.12) | no s. 40(3.12) ruling given re loss on fund LP wind-up | ||
| Income Tax Act - Section 40 - Subsection 40(3.3) | refusal to rule where shares received on LP s. 98(3) wind-up immediately sold to Carry LP owned by owners of former general partner | ||
| 2004-01-30 | 19 January 2004 Internal T.I. 2003-0045911I7 F - Camionnette et définition de automobile | Income Tax Act - Section 248 - Subsection 248(1) - Automobile | application of s. 13(5) where extended-cab pick-up truck ceased to be an automobile |
| Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(g) | s. 13(7)(g) limitation was preserved when pick-up truck transferred from Class 10.1 to 10 | ||
| Income Tax Act - Section 13 - Subsection 13(5) - Paragraph 13(5)(a) | when truck is transferred from Class 10.1 to 10, the capital cost as originally limited under s. 13(7)(g) is used for Class 10 purposes | ||
| 22 January 2004 Internal T.I. 2003-0054781I7 F - Reçu de don pour une partie de la valeur | Income Tax Act - Section 248 - Subsection 248(32) | de minimis threshold policy inapplicable where meal was part of what the ticket to the event was paid for | |
| 2004-01-23 | 14 January 2004 External T.I. 2003-0026011E5 F - Contrat à terme sur indice boursier | Income Tax Act - Section 54 - Adjusted Cost Base | unrealized gains or losses on stock index futures contracts not included in the ACB of such property |
| Income Tax Act - Section 233.3 - Subsection 233.3(1) - Specified Foreign Property - Paragraph (a) | foreign currency "variable margin" accounts held by registered plans with dealers are foreign property | ||
| 14 January 2004 External T.I. 2003-0029571E5 F - Attribution - société de personnes | Income Tax Act - 101-110 - Section 103 - Subsection 103(1.1) | allocation of farming partnership income did not appear reasonable | |
| Income Tax Act - Section 74.1 - Subsection 74.1(1) | s. 74.1(1) would not apply where farming income is transferred to spouse where she subscribed a nominal amount for farm partnership interest | ||
| 16 January 2004 External T.I. 2003-0046491E5 F - Allocation de retraite | Income Tax Act - Section 60 - Paragraph 60(j.1) | severance pay was not retiring allowance | |
| 14 January 2004 Internal T.I. 2003-0049531I7 F - Valeur de rachat - police d'assurance | Income Tax Act - Section 181 - Subsection 181(1) - Long-Term Debt - Paragraph (b) | insurance policy is not long-term debt of the insurer, although prepaid premium deposits might be |