We have translated 6 more CRA interpretations
27 November 2023 - 11:16pm
Email this ContentWe have translated 6 further CRA interpretations released during August and July of 2002. Their descriptors and links appear below.
These are additions to our set of 2,648 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 21 1/3 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 |
|---|---|---|---|
| 2002-08-30 | 13 August 2002 External T.I. 2002-0143255 F - Par. 70(6)(b) | Income Tax Act - Section 70 - Subsection 70(6) - Paragraph 70(6)(b) | retained income treated as capital for s. 70(6)(b) purposes in subsequent years/ direct payment of spouse’s expenses with express or implied consent is permissible |
| 20 August 2002 External T.I. 2002-0145225 F - Contingent Right to Acquire Shares | Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) | s. 251(5)(b) not applied iteratively, where shareholders have a pro rata right to acquire another’s shares, and a contingent right to acquire those shares not taken up in the 1st round | |
| 17 September 2002 Internal T.I. 2002-0149147 F - SERVICES MEDICAUX-TEMOIGNAGE | Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(a) | physician’s court testimony was not medical services | |
| 2002-08-02 | 12 August 2002 External T.I. 2002-0150095 F - Capital Dividend Account | Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (d) | surrogatum principle not applied to damages received from insurance company for alleged default in paying life insurance proceeds |
| 16 August 2002 Internal T.I. 2002-0156577 F - ASSURANCE - INVALIDITE - PARITE | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) | previous contributions could be deducted from subsequent equalization adjustment received | |
| 2002-07-19 | 14 August 2002 External T.I. 2001-0116385 F - PARTAGE DE COMMISSIONS | Income Tax Act - Section 56 - Subsection 56(2) | a reasonable portion of mutual fund commissions received by a firm should be allocated to its representative who made the sales |