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These are additions to our set of 1,915 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 16 ½ years of releases of such items by the Directorate. ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2005-02-18 16 February 2005 External T.I. 2004-0097161E5 F- Fin d'exercice d'une société de personnes Income Tax Act- Section 249.1- Subsection 249.1(4)- Paragraph 249.1(4)(b) requirement that there not be a multi-tier partnership must be satisfied each fiscal period 8 February 2005 Internal T.I. 2004-0099681I7 F- Remboursement de frais de déménagement Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) reimbursement of reasonable living expenses incurred until the employee permanently occupies new home in employer’s area is not a benefit 16 February 2005 Internal T.I. 2004-0105401I7 F- Frais de publicité Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Income-Producing Purpose costs of commenting on an issue unrelated to the business were non-deductible 17 September 1998 External T.I. 98222950 F- Régime d'accession à la propriété- habitation admissible Income Tax Act- Section 146.01- Subsection 146.01(1)- Qualifying Home qualifying home can be part of a larger commercial buildingAlso referred to as 9822295 17 February 2005 External T.I. 2004-0090411E5 F- Bien de remplacement-dispos. involontaire Income Tax Act- Section 44- Subsection 44(5)- Paragraph 44(5)(a.1) replacement property potentially can be held through a partnership if the partnership property is physically similar Income Tax Act- Section 13- Subsection 13(4) rollover not available where building replaced by interest in partnership carrying on a similar business because the partnership interest is not depreciable property 2005-02-11 2 February 2005 External T.I. 2004-0104671E5 F- Convention de retraite- Fonds mis de côté Income Tax Act- Section 248- Subsection 248(1)- Salary Deferral Arrangement amounts agreed to be paid post-retirement do not create an SDA if they are not reasonably regarded as deferred salary Income Tax Act- Section 248- Subsection 248(1)- Retirement Compensation Arrangement no requirement that payment to the other be in trust 3 February 2005 External T.I. 2005-0111871E5 F- Intérêts / mise à part de l'argent Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c)- Subparagraph 20(1)(c)(i) cash damming to pay current deductible business expenses is an eligible use which continues with the business 3 February 2005 External T.I. 2005-0112141E5 F- Safe income Income Tax Act- Section 55- Subsection 55(2.1)- Paragraph 55(2.1)(c) safe income prorated on a partial crystallization of an accrued gain ...

Bundle Date Translated severed letter Summaries under Summary descriptor 2005-01-14 10 January 2005 External T.I. 2004-0095361E5 F- Dommages Income Tax Act- Section 3- Paragraph 3(a) courts have preferred to tax on the basis of an identified source Income Tax Act- Section 56- Subsection 56(1)- Paragraph 56(1)(a)- Subparagraph 56(1)(a)(i) damages for negligence resulting in not becoming entitled to QPP would not be income under s. 56(1)(a)(i) 6 January 2005 Internal T.I. 2004-0100241I7 F- Imposition des rentes au décès Income Tax Act- Section 148- Subsection 148(2)- Paragraph 148(2)(b) no disposition of PAC under s. 148(2)(b) – but disposition if estate elects to commute Income Tax Act- Section 148- Subsection 148(9)- Proceeds of Disposition- Paragraph (d) disposition gain based on accumulating fund 2005-01-07 21 December 2004 External T.I. 2004-0085481E5 F- Titres détenus par une compagnie d'assurance Income Tax Act- Section 142.2- Subsection 142.2(1)- Mark-to-Market Property MFT units not mark-to-market property Income Tax Act- Section 248- Subsection 248(1)- Inventory per Friesen, securities held on income account are inventory 21 December 2004 External T.I. 2004-0091011E5 F- Déductibilité-primes d'assurance-responsabilité Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(a)- Start-Up and Liquidation Costs premiums for professional liability coverage incurred after the cessation of practice for continued coverage re that practice, are deductible 21 December 2004 External T.I. 2004-0093361E5 F- Report de l'impôt minimum de remplacement-décès Income Tax Act- Section 120.2- Subsection 120.2(2) if the tax generated in the terminal year is insufficient to recover the AMT paid in the preceding year, the deceased individual can no longer utilize a s. 120.2(2) carryback 21 December 2004 Internal T.I. 2004-0096211I7 F- Remise de dettes Income Tax Act- Section 80.01- Subsection 80.01(4) no need for s. 80.01(4) election if assets of sub in the amount of the debt owing to the parent are distributed on the winding up in payment of that debt 16 December 2004 Internal T.I. 2004-0100891I7 F- Prestations d'assistance sociale Income Tax Act- Section 81- Subsection 81(1)- Paragraph 81(1)(h) government and user-funded assistance with accommodation and care while attending psychiatric day hospital was exempted 16 December 2004 Internal T.I. 2004-0098631I7 F- Déduction- Résidence des membres du clergé Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(c) based on Noseworthy, RC lay pastoral workers (in one case, authorized to baptize on occasion) were not regular ministers ...

S. 84.1(2.3)(a) provides that, for the purposes of s. 84.1(2)(e): (a) if, otherwise than by reason of death, the purchaser corporation disposes of the subject shares within 60 months of their purchase: (i) paragraph [84.1](2)(e)] is deemed never to have applied, [and] (ii) the taxpayer is deemed, for the purposes of [s. 84.1], to have disposed of the subject shares to the person who acquired them from the purchaser corporation …. ...

These are additions to our set of 2,191 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 18 ¼ years of releases of such items by the Directorate. ...

These are additions to our set of 2,200 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 18 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,208 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 18 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,224 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 18 ½ years of releases of such items by the Directorate. ...

These are additions to our set of 2,249 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 18 ¾ years of releases of such items by the Directorate. ...

Summary of 5 August 2022 External T.I. 2021-0877051E5 F under s. 120.4(1) – related business. ...