We have translated 7 more CRA interpretations

8 July 2025 - 12:13am
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We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in June of 2000. Their descriptors and links appear below.

These are additions to our set of 3,247 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 25 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
2025-07-02 29 April 2025 External T.I. 2024-1036641E5 F - Relevant Group Entity Income Tax Act - Section 84.1 - Subsection 84.1(2.31) - Paragraph 84.1(2.31)(c) - Subparagraph 84.1(2.31)(c)(iii) a Realtyco, whose shares qualified as QSBCS based on a related corporation’s active business, would be a “relevant group entity” on a sale of the latter’s shares
Income Tax Act - Section 84.1 - Subsection 84.1(2.32) - Paragraph 84.1(2.32)(c) - Subparagraph 84.1(2.32)(c)(iii) continued control of the related lessor to an Opco would violate the s. 84.1(2.32)(c)(iii) condition on a sale of Opco to a child’s purchaser corporation
2000-06-23 10 May 2000 Internal T.I. 2000-0016257 F - RPA COTISATIONS POUR SERVICES ANTERIEURS Income Tax Act - Section 147.2 - Subsection 147.2(4) - Paragraph 147.2(4)(c) no retroactive deduction
19 May 2000 Internal T.I. 2000-0018477 F - DEDUCTION A LA SOURCE Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(j) amounts paid out of RRSP to trustee in bankruptcy pursuant to judgment were subject to source deductions even though no mention thereof in court order
2000-06-09 8 June 2000 External T.I. 1999-0006105 F - TRANSFERT DE BIENS A UN CONJOINT Income Tax Act - Section 74.1 - Subsection 74.1(1) CCRA has not yet developed a position re where the transferred property itself is returned to the transferor spouse in repayment of the transferee spouse’s debt
15 May 2000 Income Tax Severed Letter 2000-0008210 F - ADMINISTRATEUR DE FACTO Income Tax Act - Section 227.1 - Subsection 227.1(1) individual can be a de facto director who acts as such with the shareholders’ agreement or takes significant actions with 3rd parties in the corporation’s name
31 May 2000 External T.I. 2000-0009695 F - FRAIS MEDICAUX-PREPOSE A PLEIN TEMPS Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(b) meaning of “one full-time attendant … for the full-time care of the individual”
5 June 2000 External T.I. 2000-0010615 F - Developpement d'un equipement - RS&DE Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(d) expenditures to develop SR&ED equipment could be current expenses