We have translated 7 more CRA interpretations
4 July 2023 - 12:30am
Email this ContentWe have translated a translation of a CRA interpretation released last week and a further 6 translations of CRA interpretations released in April of 2003. Their descriptors and links appear below.
These are additions to our set of 2,515 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 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 |
|---|---|---|---|
| 2023-06-28 | 13 March 2023 External T.I. 2019-0802271E5 F - Déduction supplémentaire prévue au sous-alinéa 110 | Income Tax Regulations - Regulation 1100 - Subsection 1100(1) - Paragraph 1100(1)(c.1) | transferring Class 14.1 property under s. 98(3) eliminates any additional Reg. 1100(1)(c.1)(i) CCA claims |
| 2003-04-11 | 9 April 2003 Internal T.I. 2003-0001597 F - FRAIS ACCESSOIRES
Also released under document number 2003-00015970.
|
Income Tax Act - Section 18 - Subsection 18(3.1) | application of s. 18(3.1) to work on a rental property |
| 2 April 2003 External T.I. 2003-0002285 F - FRAIS OBLIGATOIRE SERVICE INFORMATIQUE
Also released under document number 2003-00022850.
|
Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(a) | fees rendered by the university’s computer department for services are includible in tuition fees | |
| 1 April 2003 External T.I. 2003-0004125 F - Freeze by Paying a Stock Dividend
Also released under document number 2003-00041250.
|
Income Tax Act - Section 74.4 - Subsection 74.4(2) | non-application to stock dividend | |
| Income Tax Act - Section 15 - Subsection 15(1.1) | s. 15(1.1) inapplicable to stock dividend paid to wholly-owning shareholder | ||
| Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | imputed disposition to which s. 69(1)(b) applied where common shares issued at undervaluation to children’s trust | ||
| General Concepts - Effective Date | price-adjustment clause to redemption value of preferred shares did not accord with IT-169 | ||
| 8 April 2003 Internal T.I. 2003-0004827 F - Avantage conféré par une fiducie-par. 105(1)
Also released under document number 2003-00048270.
|
Income Tax Act - 101-110 - Section 105 - Subsection 105(1) | s. 105(1) benefit can be conferred by trust on a tenant who is not a beneficiary/ benefit to be based on fair rental value at the time the deceased entered into the lease | |
| 2 April 2003 External T.I. 2002-0171215 F - FRAIS DE FINANCEMENT
Also released under document number 2002-01712150.
|
Income Tax Act - Section 18 - Subsection 18(3.1) | treatment of CMHC guarantee fees and interest rate guarantee fee | |
| 2003-04-04 | 31 March 2003 External T.I. 2002-0171835 F - DON D'ACTIONS COTEES EN BOURSE
Also released under document number 2002-01718350.
|
Income Tax Act - Section 149.1 - Subsection 149.1(6.3) | donation of Pubco shares to public foundation qualified as such given that s. 149.1(6.3) designation not effective until following year |
| Income Tax Act - Section 38 - Paragraph 38(a.1) | donation of Pubco shares to public foundation qualified as such given that s. 149.1(6.3) designation not effective until following year |