We have translated 6 more CRA interpretations

21 August 2023 - 11:11pm
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We have translated 6 translations of CRA interpretations released in February of 2003. Their descriptors and links appear below.

These are additions to our set of 2,558 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 ½ 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
2003-02-21 19 February 2003 Internal T.I. 2002-0169967 F - ARREARAGES-PENSION ALIMENTAIRE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount settlement payment of past and future support payments was not a support amount
2003-02-14 11 December 2002 External T.I. 2002-0146465 F - Article XVI Canada-E.U. Treaties - Income Tax Conventions - Article 16 income earned by S Corp. of US athlete was taxable under Art. 16
28 January 2003 External T.I. 2002-0147405 F - Crédit d'impôt pour emploi à l'étranger Income Tax Act - Section 122.3 - Subsection 122.3(1) leave periods in Canada count towards the period of 6 months’ employment under foreign project if not terminated before leave commences
Income Tax Act - Section 115 - Subsection 115(1) - Paragraph 115(1)(a) - Subparagraph 115(1)(a)(i) leave period in Canada counted towards the 6-month period required under s. 122.3(1) of employment on performing services on foreign project
30 January 2003 Internal T.I. 2002-0157307 F - Article 86.1 et fractions d'action Income Tax Act - Section 86.1 - Subsection 86.1(2) - Paragraph 86.1(2)(b) distribution of fractional shares and their immediate cash sale complied with s. 86.1(2)(b)
27 January 2003 External T.I. 2002-0169385 F - Un serveur et l'établissement stable Treaties - Income Tax Conventions - Article 5 Canadian servers of Swiss company would not be a PE if sales of its product not made through the website
28 January 2003 Internal T.I. 2002-0175927 F - Choix de 107(2.001) Income Tax Act - 101-110 - Section 107 - Subsection 107(2.001) the election, which is unlike the designation in Lussier, cannot be made late