We have translated 6 more CRA interpretations
4 March 2024 - 10:26pm
Email this ContentWe have translated 6 further CRA interpretations issued in April of 2002. Their descriptors and links appear below.
These are additions to our set of 2,768 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 22 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 |
|---|---|---|---|
| 2002-03-29 | 4 April 2002 External T.I. 2001-0103525 F - Identical Property | Income Tax Act - Section 54 - Superficial Loss - Paragraph (i) | right to convert Class A shares into Class B shares would cause the loss on disposing of Class B shares, followed immediately by acquiring Class A shares, to be a denied superficial loss |
| 18 April 2002 Internal T.I. 2001-0105007 F - RECOMPENSE POUR UN SAUVETAGE MARITIME | Income Tax Act - Section 3 - Paragraph 3(a) | salvage received by crew members was not an exempt windfall | |
| Income Tax Act - Section 5 - Subsection 5(1) | salvage received by employed crew members likely employment income | ||
| 5 April 2002 External T.I. 2002-0122055 F - BIEND D'UN REER DONNES EN GARANTIE | Income Tax Act - Section 146 - Subsection 146(12) | where property used as security, s. 146(12) rather than s. 146(10) applies to a depositary RRSP | |
| Income Tax Act - Section 146 - Subsection 146(10) | s. 146(10) rather than s. 146(12) applies to a non-depositary RRSP where its property is used as security | ||
| Income Tax Act - Section 146 - Subsection 146(7) | s. 146(7) can reverse only the current year’s inclusion under s. 146(10) | ||
| 12 April 2002 External T.I. 2002-0122495 F - PRIME PAYEE SUR OBLIGATION | Income Tax Act - Section 54 - Adjusted Cost Base | premium on bond acquired as capital property produces a capital loss at maturity | |
| Income Tax Act - Section 9 - Capital Gain vs. Profit - Debt/ receivables | short holding time to maturity does not preclude a bond from being capital property | ||
| Income Tax Regulations - Regulation 7000 - Subsection 7000(1) - Paragraph 7000(1)(b) | determination of Reg. 7000(1)(b) proportions made on a taxpayer-specific basis | ||
| 11 April 2002 External T.I. 2002-0125675 F - REER DECOUVERT BANCAIRE | Income Tax Act - Section 146 - Subsection 146(4) - Paragraph 146(4)(a) | bank overdraft due to admin fee charge to RRSP could constitute money borrowed from the trust | |
| Income Tax Act - Section 146 - Subsection 146(10) | overdraft in RRSP bank account due to admin fee charge could represent the use of trust property as loan security | ||
| 21 March 2002 External T.I. 2001-0115265 F - 89(1)(c.1)(i)&(c.2)(i) Capital Div. Acc. | Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account | under revised rules, CDA from goodwill disposition can only be accessed in the following year |