We have translated 8 more CRA severed letters

17 June 2024 - 11:26pm
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We have translated a ruling and interpretation released by CRA last week and a further 6 CRA interpretations released in October of 2001. Their descriptors and links appear below.

These are additions to our set of 2,866 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 2/3 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
2024-06-12 16 April 2024 Internal T.I. 2023-0998991I7 F - Qualification fiscale de certaines sommes Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) amount per week of training in short-term program leading to a skills training certificate was a bursary/ amount paid upon graduation was a bursary or a prize
2024 Ruling 2023-0989121R3 F - Internal reorganization - 55(3)(a) and 55(3.01)(g) Income Tax Act - Section 55 - Subsection 55(3.01) - Paragraph 55(3.01)(g) transfer of real estate to separate Realtyco beneath a newly-formed Holdco
Income Tax Act - Section 75 - Subsection 75(2) 2 unrelated individuals were the settlors for each other’s family trust
Income Tax Act - Section 248 - Subsection 248(10) estate freeze transactions represented to be independent of subsequent transfer
Income Tax Act - Section 55 - Subsection 55(3) - Paragraph 55(3)(a) - Subparagraph 55(3)(a)(ii) s. 55(3.01)(g) applied to the transfer (fresh after an estate freeze) by unrelated shareholders of Opco to a new Holdco, with an Opco realty spin-off to a new Realtyco sister
2001-10-26 14 November 2001 External T.I. 2001-0086765 F - FRAIS DE REPRESENTATION-EXCEPTION Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(c) s. 67.1(2)(c) exception is not precluded where the specific reimburser is a non-resident
8 November 2001 External T.I. 2001-0096435 F - Sous-alinéa 75(2)(a)(i) de la Loi Income Tax Act - Section 75 - Subsection 75(2) - Paragraph 75(2)(a) - Subparagraph 75(2)(a)(i) s. 75(2) does not apply by virtue of the trust property reverting to the settlor by operation of law
8 November 2001 External T.I. 2001-0103375 F - Décès du rentier Income Tax Act - Section 70 - Subsection 70(3) s.60(l)(ii)(B) annuity amounts, or entitlements thereto as trust income beneficiary, were rights and things
7 November 2001 External T.I. 2001-0103805 F - SENS D'ACTIFS Income Tax Act - Section 61.3 - Subsection 61.3(1) - Paragraph 61.3(1)(b) future income tax asset under GAAP is an asset
2 November 2001 External T.I. 2001-0107425 F - FONDS RESERVES ET BIENS ETRANGERS Income Tax Act - Section 206 timing of foreign property rules for segregated funds
6 November 2001 External T.I. 2001-0072335 F - CII-LOCATION Income Tax Act - Section 127 - Subsection 127(9) - Qualified Property - Paragraph (d) lessor can qualify for ITC even if lease is assigned to finance company immediately after the lease