Principal Questions: Whether there is an error in the french translation of paragraph 23 in IT-419R?
Position: Yes.
Reasons: The English expression "not dealing at arm's length" was translated in French with the expression "sans lien de dépendance" which is the opposite of not dealing at arm's length. Measures were taken to rectify the error at the first opportunity.
September 15, 2010
Mr. Ludovic Landry Headquarters
CPP/EI Rulings Officer Marc LeBlondEastern Quebec Tax Services Office
100, Lafontaine
Chicoutimi QC G7H 6X2
2010-037152
Paragraph 23 of Interpretation Bulletin IT-419R2
This is in response to your email of June 18, 2010 in which you brought to our attention a discrepancy between the English and French versions of paragraph 23 in Interpretation Bulletin IT-419R2 ("IT-419R2").
In your e-mail, you point out that the expression "not dealing at arm's length", in the English version of paragraph 23 in IT-419R2, and the expression "sans lien de dépendance", in the French version of the same bulletin, actually have opposite meanings.
We agree with you and have already taken steps to ensure that the text of the French version of IT-419R2 is corrected at the earliest opportunity.
Thank you for bringing this matter to our attention.
Maurice Bisson, CGA
Manager
Corporate Reorganizations and Resource Industries Section
Corporate Reorganizations and Resource Industries Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch.