We have translated 6 more CRA interpretations

8 January 2024 - 12:50am
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We have translated 6 further CRA interpretations released during June of 2002. Their descriptors and links appear below.

These are additions to our set of 2,688 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
2002-06-07 11 June 2002 External T.I. 2001-0104075 F - DEDOMMAGEMENT Income Tax Act - Section 54 - Adjusted Cost Base damages award not part of cost if subject to an appeal
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(e) damages award not recognized until appeal thereof heard
17 June 2002 Internal T.I. 2001-0111717 F - BFT ET CONSTRUCTION MAISON EN USINE Income Tax Act - Section 125.1 - Subsection 125.1(3) - Manufacturing or Processing - Paragraph (c) fabricator of manufactured homes was not excluded for engaging in “construction”
18 April 2002 Internal T.I. 2002-0118827 F - DEBENTURES CONVERTIBLES
see also 2002-0130177 F

 Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) no s. 20(1)(f)(ii) deduction on conversion of convertible debentures notwithstanding attempt in resolution to fix the issued shares’ stated capital at their market value
Income Tax Act - Section 89 - Subsection 89(1) - Paid-Up Capital PUC of shares issued on debenture conversion equal to consideration stated in debenture indenture and in financial statements, rather than the FMV of shares stated in resolution
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Financing Expenditures premium on redemption of convertible debentures was not deductible on current account
Income Tax Act - Section 18 - Subsection 18(9.1) straight-line or present value method may be used in amortizing premium, and must relate to interest
20 June 2002 External T.I. 2002-0120245 F - CREDIT D'IMPOT PERSONNELS Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) general requirements
31 May 2002 Internal T.I. 2002-0131647 F - REPORT CREDITS FRAIS SCOLARITE Income Tax Act - Section 118.61 - Subsection 118.61(1) deductible credits which are not used cannot be carried forward
20 June 2002 External T.I. 2002-0140895 F - PRESTATION AU DECES Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit amount was not a taxable death benefit and was in substance insurance proceeds