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6 more translated CRA interpretations are available [corrected]

Bundle Date Translated severed letter Summaries under Summary descriptor 2019-07-10 4 June 2019 Internal T.I. 2018-0783441I7 F- Sale of land by a resident of Hong Kong Treaties- Income Tax Conventions- Article 13 Canadian land was not Treaty-exempt even where it did not generate income 2011-11-25 7 November 2011 Internal T.I. 2011-0424641I7 F- Right to cut Christmas trees Income Tax Act- Section 13- Subsection 13(21)- Timber Resource Property right to cut Christmas trees was not a timber resource property Income Tax Regulations- Regulation 1100- Subsection 1100(1)- Paragraph 1100(1)(e) Christmas trees are not “timber” Income Tax Regulations- Schedules- Schedule II- Class 14 right to cut Christmas trees with 10-year term was a Class 14 property 7 October 2011 Roundtable, 2011-0411871C6 F- Employé constitué en société Income Tax Act- Section 125- Subsection 125(7)- Personal Services Business PSB can have two spouses as incorporated employees 7 October 2011 Roundtable, 2011-0411841C6 F- Succession Income Tax Act- 101-110- Section 104- Subsection 104(1) estate could cease when assets converted to cash and liabilities settled 7 October 2011 Roundtable, 2011-0412091C6 F- Late Filed Paragraph 55(5)(f) Designation Income Tax Act- Section 55- Subsection 55(5)- Paragraph 55(5)(f) CRA practice to only treat excess of taxable dividend over safe income as subject to s. 55(2) 7 October 2011 Roundtable, 2011-0411891C6 F- Dépenses- EPSP- négociant en vente Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(p)- Sjubparagraph 18(1)(p)(iii) s. 18(1)(p)(iii) deduction limited to commission income Income Tax Act- Section 8- Subsection 8(13) home office of a PSP corporation’s employee could qualify ...

Addy – Federal Court of Australia finds that the imposition of flat tax on UK working-holiday visa holders contravened the Treaty non-discrimination Article

Summaries of Addy v Commissioner of Taxation [2019] FCA 1768 under Treaties – Income Tax Conventions – Art. 25 and ITA s. 2(1). ...

Wolf – Federal Court of Appeal questions Tax Court view that an individual could derive business revenues through an LLC

Canada, 2019 FCA 283 under Treaties – Income Tax Conventions – Art. 5. ...

A U.S. amendment effectively denying an FTC for Canadian taxes imposed on profits of a U.S. producer on sales into Canada may override the Treaty

Summaries of Nathan Boidman, “Will Revised Code Section 863 Be Constrained by the Canadian Treaty on Sales of Inventory into Canada,” Article for Tax Notes International, 3 February 2020 under Treaties – Income Tax Conventions – Art. 7, Art. 24, ITA s. 115(1)(a)(ii). ...

5 more translated CRA interpretations are available

Bundle Date Translated severed letter Summaries under Summary descriptor 2010-10-22 28 September 2010 External T.I. 2010-0357141E5 F- Prix de présence et tirages Income Tax Act- Section 6- Subsection 6(1)- Paragraph 6(1)(a) promotional prize as income to employee of third party Income Tax Act- Section 9- Nature of Income business income from draw won by brokerage 4 October 2010 External T.I. 2010-0367231E5 F- Convention de partage d'une société de personnes Income Tax Act- 101-110- Section 103- Subsection 103(1.1) s. 103(1) or (1.1) could apply to allocation of ordinary income and capital gains on substantially different basis between couple and their corporation 6 October 2010 External T.I. 2008-0302951E5 F- Stagiaires postdoctoraux Income Tax Act- Section 56- Subsection 56(3)- Paragraph 56(3)(a)- Subparagraph 56(3)(a)(ii) postdoctoral fellows are ineligible for the full scholarship exemption 12 October 2010 External T.I. 2010-0371931E5 F- T5 Information Returns Income Tax Regulations- Regulation 201- Subsection 201(4) T5 slip should report Reg. 7000 interest and interest coupon payments net of previous accruals thereof 12 October 2010 Internal T.I. 2010-0355761I7 F- PCMC- Dépense courante ou en capital Income Tax Act- Section 18- Subsection 18(1)- Paragraph 18(1)(b)- Capital Expenditure v. ...

We have translated 4 more CRA Interpretations

Bundle Date Translated severed letter Summaries under Summary descriptor 2009-06-26 27 May 2009 External T.I. 2008-0296731E5 F- Rachat d'actions: 20(1)c) Income Tax Act- Section 20- Subsection 20(1)- Paragraph 20(1)(c) corporation must allocate contributed capital of redeemed shares proportionately to borrowed money and redemption notes, but can disproportionately allocate its accumulated profits 12 June 2009 External T.I. 2009-0316511E5 F- Charges sociales et autres retenues France Treaties- Income Tax Conventions- Article 18 list of pension plans recognized for French tax purposes re Art. ...

CRA expands its positions on spouse trusts in a new Folio

Summaries of Folio S6-F4-C1, “Testamentary Spouse or Common-law Partner Trusts,” 3 February 2022 under s. 70(6)(b), s. 70(6.2), s. 248(1)- Common-Law Partner, s. 248(9.1), s. 108(3), s. 70(8)(c), s.70(7), s. 70(6.1), Treaties – Income Tax Conventions- Art. 29 B and s. 104(13.4)(b.1). ...

Marin – Tax Court of Canada confirms that FTC domestic and Treaty provisions are applied re the particular year in which the subject income was earned

The Queen, 2022 CCI 49 under s. 126(7) – non-business income tax, Treaties – Income Tax Conventions, Art. 6, Art. 24. ...

Levett – Federal Court of Appeal finds that taxpayer stonewalling satisfied the Swiss exchange-of-information requirement that CRA had “pursued all reasonable [domestic] means available”

Canada (Attorney General), 2022 FCA 117 under Treaties –Income Tax Conventions- Art. 27. ...

CRA requires proof that a Barbados remittance-based resident has borne tax on Canadian dividend income before providing the Treaty rate reduction

Summaries of 5 October 2021 Internal T.I. 2021-0903361I7 under Treaties – Income Tax Conventions – Art. 4, Art. 29. ...

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