We have translated 6 more CRA interpretations

We have published a further 6 translations of CRA interpretations released in July of 2003. Their descriptors and links appear below.

These are additions to our set of 2,438 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 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
2003-07-11 13 June 2003 External T.I. 2002-0156435 F - ASSURANCE DE MALADIES REDOUTEES
Also released under document number 2002-01564350.

Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) taxable benefit from critical illness coverage if it is incidental to life insurance coverage
Income Tax Act - Section 248 - Subsection 248(1) - Group Term Life Insurance Policy group life insurance policy that includes critical illness coverage is not a "group term life insurance policy"
Income Tax Act - Section 148 - Subsection 148(9) - Disposition - Paragraph (e) critical illness benefit paid under a life insurance policy is proceeds of disposition
27 June 2003 External T.I. 2003-0019095 F - RACHAT DE SERVICES PASSES
Also released under document number 2003-00190950.

Income Tax Act - Section 147.2 - Subsection 147.2(4) - Paragraph 147.2(4)(c) overview of ss. 147.2(4)(b) and (c)
25 June 2003 External T.I. 2003-0024465 F - PARTIE XI.1 BIENS NON-ADMISSIBLES
Also released under document number 2003-00244650.

Income Tax Act - Section 207.1 - Subsection 207.1(1) no discretion in CCRA to waive the tax under s. 207.1
2003-07-08 7 July 2003 External T.I. 2001-0091415 F - Income & Losses from Bus. or Prop. Sec. 9 ITA
Also released under document number 2001-00914150.

Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(a) prepaid crypt fees of funeral home were includible under s. 12(1)(a)
Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(m) prepaid crypt fees of funeral home were ineligible for s. 20(1)(m) reserve
26 June 2003 External T.I. 2003-0021595 F - Distribution of Corporate Property
Also released under document number 2003-00215950.

Income Tax Act - 101-110 - Section 107 - Subsection 107(2.1) illustration of application, by virtue of s. 107(2.001) election, of s. 107(2.1) to distribution of CCPC shares
Income Tax Act - Section 84 - Subsection 84(2) s. 84(2) inapplicable to s. 107(2.1) wind-up of trust holding a Portfolioco followed by an inter vivos pipeline transaction re Portfolioco
Income Tax Act - Section 55 - Subsection 55(1) - Safe-Income Determination Time s. 107(2.1) wind-up of trust holding a Portfolioco would trigger a safe-income determination time if with a view to an inter vivos pipeline transaction with a s. 88(2) wind-up of Portfolioco
16 July 2003 Internal T.I. 2003-0024617 F - DEDUCTIBILITE DES COTISATIONS CSST
Also released under document number 2003-00246170.

Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) estimated workers’ compensation premium liabilities were currently deductible