We have translated 6 more CRA severed letters
5 December 2022 - 11:16pm
Email this ContentWe have published a translations of a ruling released by CRA last week and a further 5 translations of CRA interpretations released in January of 2004. Their descriptors and links appear below.
These are additions to our set of 2,296 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 |
|---|---|---|---|
| 2022-11-30 | 2022 Ruling 2022-0930901R3 F - Changes to an existing monetization arrangement | Income Tax Act - Section 80.6 | partial acceleration of a forward contract did not de-grandfather it from the synthetic disposition rules |
| 2004-01-09 | 17 December 2003 Internal T.I. 2003-0047367 F - Benefit Conferred on Non-arm's Length Person | Income Tax Act - Section 246 - Subsection 246(1) | s. 246(1) applicable to sale of assets by corporation to employee-shareholder at an undervalue |
| Income Tax Act - Section 52 - Subsection 52(1) | application of s. 15(1) or 246(1) to property distributed by corporation to shareholder would be added to the property’s ACB | ||
| Income Tax Act - Section 84 - Subsection 84(2) | s. 84(2) inapplicable on sale by defunct corporation of its assets at an undervalue to one of its shareholders | ||
| 17 December 2003 Internal T.I. 2003-0047727 F - Right of Use-Deemed Trust | Income Tax Act - 101-110 - Section 105 - Subsection 105(1) | no s. 105(1) benefit from personal use of personal-use property of a trust | |
| Income Tax Act - 101-110 - Section 105 - Subsection 105(2) | potential s. 105(2) benefit where Opco pays all of the expenses on its property to a portion of which the sister of Opco’s indirect controlling shareholder has a right of (personal) use | ||
| 9 December 2003 External T.I. 2003-0032585 - Immeuble détenu par une succession | Income Tax Act - Section 54 - Principal Residence - Paragraph (c.1) | income beneficiary of estate could be a specified beneficiary using as principal residence | |
| Income Tax Act - 101-110 - Section 107 - Subsection 107(2) | s. 107(2) rollover unavailable to an income beneficiary | ||
| 18 December 2003 Internal T.I. 2003-0044007 F - OPTION D'ACHAT D'ACTIONS RACHETEES | Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | full option surrender consideration included under s. 7(1)(b) even though a portion thereof never paid | |
| Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | unpaid and defaulted balance of stock option surrender consideration was not property used in a property or business source | ||
| Income Tax Act - Section 54 - Capital Property | employee stock option surrender proceeds were not from the disposition of capital property |