We have translated 6 more CRA interpretations

13 August 2024 - 12:17am
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We have translated a further 6 CRA interpretations released in September of 2001. Their descriptors and links appear below.

These are additions to our set of 2,916 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
2001-09-28 3 May 2001 External T.I. 2001-0069535 F - DEPENSE D'INTERET REGLES D'ATTRIBUTION Income Tax Act - Section 74.5 - Subsection 74.5(11) potential application of s. 74.5(11) to leveraged s. 73(1) property transfer to spouse
11 October 2001 Internal T.I. 2001-0079197 F - pension alimentaire Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day - Paragraph (b) - Subparagraph (b)(ii) suspension of support did not trigger a commencement day
Income Tax Act - Section 56.1 - Subsection 56.1(3) post-May 1997 temporary custody order triggered a commencement day
8 October 2001 Internal T.I. 2001-0086177 F - FRAIS DE SCOLARITE Income Tax Act - Section 118.5 - Subsection 118.5(1) - Paragraph 118.5(1)(a) - Subparagraph 118.5(1)(a)(ii.2) - Clause 118.5(1)(a)(ii.2)(B) English instruction did not qualify as occupational development under s. 118.5(1)(a)(ii.2)
16 August 2001 Internal T.I. 2001-0079317 F - RESIDENCE PRINCIPALE DEMI-HECTARE Income Tax Act - Section 54 - Principal Residence - Paragraph (e) exemption could be claimed only for one lot/ CCRA does not normally challenge contribution to enjoyment of residence of under ½ hectare if no commercial use
3 May 2001 Internal T.I. 2001-0081837 F - BILLET CONVERTIBLES PRINCIPAL
2001-0081837 F and 2000-0046367 F are similar.

 Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(f) corporation was considered to have paid an amount on conversion of convertible notes equal to their face amount and stated capital of the issued shares
18 September 2001 Internal T.I. 2001-0082997 F - COTISATIONS PATRONALES REGIME DIFFERES Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense Fédération case does not impact the deductibility of contributions to various deferred compensation plans