We have translated 6 more CRA interpretations
19 December 2022 - 11:23pm
Email this ContentWe have published a further 6 translations of CRA interpretations released in January of 2004 and December of 2003.Their descriptors and links appear below.
These are additions to our set of 2,305 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 19 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 |
|---|---|---|---|
| 2004-01-02 | 10 December 2003 Internal T.I. 2003-0047467 F - DESENREGISTREMENT D'UN REER
Also released under document number 2003-00474670.
|
Income Tax Act - Section 146 - Subsection 146(12) - Paragraph 146(12)(b) | appraiser not required, but issuer must make reasonable efforts to determine FMV of shares of illiquid co-op |
| Income Tax Regulations - Regulation 103 - Subsection 103(6) - Paragraph 106(6)(d) | no source deductions required where property is distributed in year subsequent to RRSP deregistration | ||
| 10 December 2003 External T.I. 2003-0023335 F - COUT D'UN BIEN REMIS EN RECOMPENSE
Also released under document number 2003-00233350.
|
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | $500 gift policy applies where parent incurs the cost (which must include any customs and shipping costs) | |
| 18 December 2003 Internal T.I. 2003-0045227 F - FRAIS JURIDIQUES-PENSION
Also released under document number 2003-00452270.
|
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | legal fees in relation to determining revised support entitlements were non-deductible | |
| 2003-12-05 | 21 November 2003 External T.I. 2003-0010195 F - Etablissement Stable
Also released under document number 2003-00101950.
|
Income Tax Regulations - Regulation 400 - Subsection 400(2) - Paragraph 400(2)(e) | use of substantial equipment in a province for even one day triggers a PE |
| 21 November 2003 External T.I. 2003-0023925 F - Distribution non-admissible au sens de 86.1
Also released under document number 2003-00239250.
|
Income Tax Act - Section 86.1 - Subsection 86.1(2) - Paragraph 86.1(2)(b) | distribution did not qualify because distributed shares were not pre-owned by Mexican distributor | |
| Income Tax Act - Section 52 - Subsection 52(2) | distributed shares had ACB equal to the s. 90 inclusion of their FMV | ||
| 28 November 2003 External T.I. 2003-0046025 F - CONVENTION DE RETRAITE DEDUCTIONS
Also released under document number 2003-00460250.
|
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(r) | s. 20(1)(r) deduction is limited by s. 67 |