We have translated 8 more CRA severed letters
27 December 2023 - 11:10pm
Email this ContentWe have translated a CRA ruling released at the end of November and an interpretation released last week along with a further 6 CRA interpretations released during June of 2002. Their descriptors and links appear below.
These are additions to our set of 2,676 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 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 |
|---|---|---|---|
| 2023-12-20 | 6 November 2019 Internal T.I. 2019-0798021I7 F - Assessment under 159(3) | Income Tax Act - Section 159 - Subsection 159(3) | trustees were liable under s. 159(3) notwithstanding having obtained a post-distribution s. 159(2) certificate |
| 2023-11-29 | 2023 Ruling 2022-0923451R3 F - 55(3)(a) internal reorganization | Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) | indirect spin-off of subsidiary groups to 2 transferee corporations held by holding companies for 2 brothers while such transferee corporations are controlled by father with special voting shares |
| Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) | proration of DSI on s. 55(3)(a) spin-offs based on the net cost amount of the property spun off | ||
| 2002-06-21 | 9 July 2002 External T.I. 2002-0147985 F - ACTIONS PRIVILEGIEES CONVERTIBLES | Income Tax Act - Section 7 - Subsection 7(1.5) | no disposition for purposes of s. 7(1.5) when employee’s preferred shares converted to common shares |
| Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) | s. 7(1)(a) benefit when employee’s convertible preferred shares converted to common shares | ||
| 5 July 2002 External T.I. 2002-0121115 F - CREDIT-BAIL | Income Tax Act - Section 13 - Subsection 13(21) - Depreciable Property | lessor rather than lessee under a financing lease was entitled to CCA | |
| 11 July 2002 External T.I. 2002-0126795 F - RESSOURCES INTERMEDIAIRES REVENU EX | Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(h) | contributions paid to a Quebec intermediate resource have been treated as means-based assistance | |
| 11 July 2002 External T.I. 2002-0131085 F - ASSURANCE INVALIDITE | Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) | employer can pay an employee additional remuneration equal to the premiums payable by the employee under employee-pay-all plan | |
| 8 July 2002 External T.I. 2002-0131835 F - Investissements détenus à l'étranger | Treaties - Income Tax Conventions - Article 22 | Canada could tax income and gains of a Canadian resident from a French life insurance policy | |
| 8 July 2002 External T.I. 2002-0136615 F - Par. 250(5) - Déclaration de revenus | Income Tax Act - Section 250 - Subsection 250(5) | individual deemed to be non-resident by s. 250(5) is not required to report world income |