We have translated 6 more CRA interpretations

11 March 2024 - 10:46pm
Email this ContentEmail this Content

We have translated 6 further CRA interpretations issued in April of 2002. Their descriptors and links appear below.

These are additions to our set of 2,774 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 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
2002-03-29 17 April 2002 Internal T.I. 2002-0122157 F - ANNULATION D'OPTION D'ACHAT D'ACTION Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract or Option Cancellation Target’s cash-cancellation of executives' options was on capital account
11 December 2001 Internal T.I. 2001-0098827 F - ANNULATION D'UN REGIME D'OPTION
confirmed in 2002-0122157 F

 Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Contract or Option Cancellation cash settlement of employee stock options in connection with the privatization of the corporation was a capital expenditure
2002-03-15 4 April 2002 External T.I. 2001-0104065 F - PROVISION D'ENTREPRISE DANS UNE PROVINCE Income Tax Regulations - Regulation 2601 - Subsection 2601(1) Quebec partner who retired and became an Ontario employee allocated the reserve inclusion under s. 34.2(5) wholly to Ontario
9 April 2002 Internal T.I. 2001-0112817 F - RESIDENCE PRINCIPALE - VENTE D'UN DUPLEX Income Tax Act - Section 54 - Principal Residence - Paragraph (e) duplex land allocated between rental and principal residence generally based on the floor areas of the respective building portions
4 April 2002 Internal T.I. 2001-0113237 F - REMBOURSEMENT DE FRAIS MEDICAUX Income Tax Act - Section 118.2 - Subsection 118.2(3) - Paragraph 118.2(3)(b) Quebec CIMAD qualifies as reimbursement of specific expenses
4 April 2002 External T.I. 2002-0123065 F - DOMMAGES-INTERETS Income Tax Act - Section 54 - Proceeds of Disposition - Paragraph (b) compensation received by Jews for property seized 60 years previously was a windfall rather than proceeds of disposition
Income Tax Act - Section 3 - Paragraph 3(a) annuities or capital sums paid to victims of anti-Semitic persecution were not income