We have translated 8 more CRA interpretations

14 July 2025 - 11:28pm
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We have translated two CRA interpretations 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 3,255 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
2025-07-09 26 February 2025 Internal T.I. 2023-0985151I7 F - Remboursement de frais juridiques par un actionnaire à sa société / Reimbursement of legal fees by a shareholder Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense contingent dividend prospect likely did not support a deduction for an obligation to reimburse legal fees
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees the vendor’s agreed reimbursement of the sold corporation’s legal costs of a failed suit in consideration for a dividend had the suit succeeded, likely was non-deductible
Income Tax Act - Section 42 - Subsection 42(1) - Paragraph 42(1)(b) - Subparagraph 42(1)(b)(ii) s. 42(1)(b)(ii) might apply to the vendor’s agreed reimbursement, post-sale, of the sold corporation’s legal costs of a failed suit
22 May 2024 External T.I. 2024-1016211E5 F - Mineral Resource Cert - XXXXXXXXXX Income Tax Act - Section 248 - Subsection 248(1) - Mineral Resource - Paragraph (d) - Subparagraph (d)(i) NRC certification received
2000-06-09 11 May 2000 External T.I. 2000-0009605 F - Démolition d'un immeuble Income Tax Regulations - Regulation 1100 - Subsection 1100(11) Reg.1100(11) does not limit a terminal loss
Income Tax Act - Section 20 - Subsection 20(16) rental property restriction rule does not apply to a terminal loss
Income Tax Act - Section 13 - Subsection 13(21.2) s. 13(21.2) does not apply to an individual nor to a corporation demolishing a building while retaining the land for more than 30 days
Income Tax Act - Section 54 - Superficial Loss no superficial loss where demolition of building
Income Tax Act - Section 40 - Subsection 40(3.3) no suspended loss where demolition of building
15 May 2000 External T.I. 2000-0001995 F - CONGE SANS SOLDE-REGIME DISTINCT Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) payment of premiums by employee during unpaid leave did not create a separate plan, so that any benefits received would still be taxable
11 May 2000 Internal T.I. 2000-0008270 F - Perte finale disposition bâtiment Income Tax Act - Section 13 - Subsection 13(21.1) - Paragraph 13(21.1)(b) s. 13(21.1)(b) would apply to reduce terminal loss even if the land was disposed of at a loss in a previous year
24 May 2000 Internal T.I. 2000-0017677 F - PENSION ALIMENTAIRE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Support Amount payments made pursuant to a separation agreement in order to maintain a financial balance between them rather than for maintenance, were not support amounts
17 May 2000 External T.I. 1999-0011695 F - Revenu protégé - options et dividendes
follow-up in 2000-0040405 F

 Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) safe income of Pubco allocated to option granted to a minority shareholder to acquire its shares, but reduced by Pubco dividends
17 March 2000 APFF Roundtable Q. 11, 2000-0008260 F - DEDUCTION POUR PLACEMENTS Income Tax Act - Section 181.2 - Subsection 181.2(4) - Paragraph 181.2(4)(b) balance of sale, although a debt, is not a “loan or advance”/ prepaid expenses are “advances”