We have translated 6 more CRA interpretations
15 July 2024 - 11:00pm
Email this ContentWe have translated a further 6 CRA interpretations released in October of 2001. Their descriptors and links appear below.
These are additions to our set of 2,892 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 ¾ 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 |
|---|---|---|---|
| 2001-10-12 | 24 April 2001 Internal T.I. 2000-0037677 F - DEBENTURES CONVERTIBLES
2000-0046367 F has virtually identical taxpayer submissions and CRA comments. See also 2001-0081837 F.
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Income Tax Act - Section 143.3 - Subsection 143.3(3) - Paragraph 143.3(3)(a) - Subparagraph 143.3(3)(a)(ii) | under pre-s. 143.3 Act, where shares issued for property, the shares’ stated capital determines the property’s cost, whereas the cost of the shares to the shareholder is their FMV |
| 26 April 2001 Internal T.I. 2000-0046367 F - DEBENTURES CONVERTIBLES
See also 2001-0081837 F.
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Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) | shares issued on conversion of debenture for their stated capital (equal to debenture face amount) rather than higher FMV, so that they were not repaid at a premium | |
| Income Tax Act - Section 54 - Adjusted Cost Base | where shares issued for property, the shares’ stated capital determines the property’s cost, whereas the cost of the shares to the shareholder is their FMV | ||
| Income Tax Act - Section 89 - Subsection 89(1) - Paid-Up Capital | stated capital of shares issued determined in board’s discretion and may be less than their FMV | ||
| 29 March 2001 Internal T.I. 2000-0059117 F - PROVISION POUR GARANTIES | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(l.1) | partnership is not eligible for the s. 20(1)(l.1) reserve/ providing guarantees is not providing insurance | |
| 1 June 2001 Internal T.I. 2001-0067047 F - DOMMAGES DISCRIMINATION | Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | damages for loss of income from employment due to discrimination were not a retiring allowance or otherwise taxable | |
| 23 October 2001 External T.I. 2001-0092025 F - Fonds commun de placement à risques | Income Tax Act - Section 96 | French Fonds Commun de Placement à Risques was likely a co-ownership arrangement | |
| 23 October 2001 External T.I. 2001-0096525 F - transfer and loans to corp-attribution rules | Income Tax Act - Section 74.4 - Subsection 74.4(2) | spouse was a specified shareholder where she was one of the beneficiaries of a discretionary trust holding more than 10% of the corporation’s shares |