We have translated 7 more CRA severed letters
23 January 2023 - 10:58pm
We have published a translation of a recently-released CRA ruling and a further 6 translations of CRA interpretations released in November and October of 2003. Their descriptors and links appear below.
These are additions to our set of 2,346 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 ¼ 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 |
---|---|---|---|
2023-01-11 | 2021 Ruling 2020-0852541R3 F - Split-up XXXXXXXXXX Butterfly | Income Tax Act - Section 55 - Subsection 55(1) - Distribution | one-wing split-up butterfly with a preliminary cash distribution of life insurance proceeds |
Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b) | resolution of Part IV tax circularity issue on butterfly to be resolved by local TSO | ||
2003-11-07 | 27 October 2003 Internal T.I. 2003-0022887 F - CII-PECHEURS
Also released under document number 2003-00228870.
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Income Tax Act - Section 127 - Subsection 127(9) - Specified Percentage - Paragraph (a) - Subparagraph (a)(iii) | Gaspé Peninsula includes St. Lawrence |
29 October 2003 External T.I. 2003-0026355 F - ECHANGE D'ACTIONS
Also released under document number 2003-00263550.
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Income Tax Act - 101-110 - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(f) - Subparagraph 110.6(14)(f)(i) | s. 110.6(14)(f)(i) applies to shares issued as part consideration for shares of a different class transferred to the corporation on a dirty s. 85 exchange | |
5 November 2003 Internal T.I. 2003-0037977 F - FRAIS POUR ANNULER UNE OFFRE D'ACHAT
Also released under document number 2003-00379770.
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Income Tax Act - Section 40 - Subsection 40(1) - Paragraph 40(1)(a) - Subparagraph 40(1)(a)(i) | legal fees incurred to defend a repudiation of a purchase contract might be a disposition expense (of the rights to purchase) | |
31 October 2003 Internal T.I. 2003-0040997 F - CHANTIER PARTICULIER REPAS CONJOINT
Also released under document number 2003-00409970.
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Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) | s. 6(6)(a) does not extend to covering meal expenses of visiting spouses | |
2003-10-31 | 29 October 2003 External T.I. 2003-0033435 F - CREDIT POUR INTERET SUR PRETS ETUDIANTS
Also released under document number 2003-00334350.
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Income Tax Act - Section 118.62 | exclusion for amount paid in satisfaction of a judgment applies to interest that was paid during the course of the legal proceedings resulting in the judgment |
29 October 2003 External T.I. 2003-0037435 F - REMBOURSEMENT DE PAIMENTS D'UN REEE
Also released under document number 2003-00374350.
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Income Tax Act - Section 146.1 - Subsection 146.1(2) | subscriber can assign or pledge the right to receive repayments of payments |