We have translated 7 more CRA severed letters

20 January 2025 - 11:15pm
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We have translated a CRA ruling released three weeks ago and a further 6 CRA interpretations released in March and February of 2001. Their descriptors and links appear below.

These are additions to our set of 3,083 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 23 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
2024-12-31 2024 Ruling 2024-1008821R3 F - Multi-wings split-up net asset butterfly 55(3)(b) Income Tax Act - Section 55 - Subsection 55(1) - Distribution net asset split-up butterfly of DC with cash and near-cash property (defined in detail) and investment property (stock market portfolio)
Income Tax Act - Section 186 - Subsection 186(1) - Paragraph 186(1)(b) Pt. IV circularity avoided through establishing year ends for TCs before DC wound up into TCs
2001-03-02 5 February 2001 Internal T.I. 2000-0062927 F - Société civile française Income Tax Act - Section 96 French civil partnership is a partnership, not a corporation
2001-02-16 5 February 2001 External T.I. 2001-0067135 F - Dividend-General Income Tax Act - Section 84.1 - Subsection 84.1(1) application of s. 84.1 on sale of 50% shareholding to corporation owned by the transferor and his spouse
5 February 2001 External T.I. 2000-0032695 F - Convention fiscale Canada-France Treaties - Income Tax Conventions - Article 7 profits based consulting fee paid to French company with no PE in Canada was exempted under Art. 7 of the Canada-France treaty
Income Tax Act - Section 212 - Subsection 212(1) - Paragraph 212(1)(d) - Subparagraph 212(1)(d)(iii) - Clause 212(1)(d)(iii)(C) profits based consulting fee paid to French company came within s. 212(1)(d)(iii)(C)
6 February 2001 External T.I. 2000-0044095 F - Honoraires - retenue d'impôt non-résident Treaties - Income Tax Conventions - Article 7 management fees exempted from withholding by business profits article in Canada-US treaty
12 February 2001 External T.I. 2000-0056905 F - ALLOCATION POUR FRAIS DE STATIONNEMENT Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose allowances for no-receipt parking were generally deductible
Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) allowances for commuting to successive construction sites were not for travel in the course of employment
6 February 2001 External T.I. 2000-0059485 F - DBFT - Sous-traitants - textile Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits goods can be physically manufactured abroad if Canco exercises extensive involvement and control over the content, design, and physical qualities of the goods from inception to completion
Income Tax Regulations - Regulation 5202 - Qualified Activities no cost of labour or qualifying activities if the core manufacturing activities are outside Canada