We have translated 7 more CRA interpretations

12 June 2023 - 11:00pm

We have translated an interpretations released by CRA last week and a further 6 translations of CRA interpretations released in May of 2003. Their descriptors and links appear below.

These are additions to our set of 2,494 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 20 years of releases of such items by the Directorate. These translations are subject to our paywall (applicable after the 5^th of each month).

Bundle Date	Translated severed letter	Summaries under	Summary descriptor
2023-06-07	15 February 2023 External T.I. 2022-0934821E5 F - Paragraphes 1103(1) et 1101(5b.1)	Income Tax Regulations - Regulation 1103 - Subsection 1103(1)	Reg. 1103(1) election by partnership cannot extend to property included in a separate class under Reg. 1101(5b.1) election
2023-06-07		Income Tax Regulations - Regulation 1101 - Subsection 1101(5b.1)	Reg. 1101(5b.1) separate class status cannot be overridden by Reg. 1103(1) election
2003-05-09	23 April 2003 Internal T.I. 2003-0008767 F - Benefits Conferred on Shareholders Also released under document number 2003-00087670.	Income Tax Act - Section 15 - Subsection 15(1)	shareholder benefit where house sold to shareholder at a loss attributable to its having been built to his luxury specifications
		Income Tax Act - Section 54 - Personal-Use Property	house provided for use of the corporation’s shareholder (giving rise to s. 15(1) benefit) was personal-use property
		Income Tax Act - Section 46 - Subsection 46(4)	policy of s. 46(4) supported the finding of a shareholder benefit when personal-use property of corporation sold at a loss (representing luxury elements that did not add value) to its shareholder
	6 May 2003 External T.I. 2003-0181495 F - DEDUCTIBILITY DES INTERETS Also released under document number 2003-01814950.	Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i)	post-Ludco, CRA accepts that interest borrowed at a rate higher than the fixed-return for the investment, is generally deductible
2003-05-02	1 May 2003 Internal T.I. 2002-0178347 F - BENEFICES FABRICATION Also released under document number 2002-01783470.	Income Tax Regulations - Regulation 5202 - Qualified Activities	no requirement that the SR&ED be connected to M&P
		Income Tax Act - Section 9 - Expense Reimbursement	reimbursements of SR&ED labour and other expenses did not reduce cost of labour
		Income Tax Regulations - Regulation 5202 - Cost of Manufacturing and Processing Labour	reimbursements of SR&ED expenses do not reduce cost of manufacturing and processing labour
	25 April 2003 External T.I. 2002-0171075 F - AVANTAGE-POLICE D'ASSURANCE Also released under document number 2002-01710750.	Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a)	s. 6(1)(a) benefit where employer, as policyholder, pays premiums on policy on life of employee, whose estate is the revocable beneficiary
		Income Tax Act - Section 15 - Subsection 15(1)	s. 15(1) benefit where corporate policyholder pays premiums on policy on shareholder’s life where the revocable beneficiary is the shareholder’s estate
	30 April 2003 External T.I. 2002-0172485 F - LIQUIDATION SOCIETE DE PERSONNES Also released under document number 2002-01724850.	Income Tax Act - Section 85 - Subsection 85(3)	taking back note for receivables transferred under s. 22 rather than s. 85(2) precludes s. 85(3) application to wind-up
	29 April 2003 External T.I. 2002-0177065 F - CONFISCATION DE LA SOLDE Also released under document number 2002-01770650.	Income Tax Act - Section 5 - Subsection 5(1)	salary that is forfeited by RCMP officer for misconduct nonetheless is includible as salary which was constructively received
		General Concepts - Payment & Receipt	forfeited salary nonetheless includible as salary received

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We have translated 7 more CRA interpretations