We have translated 7 more CRA severed letters

21 July 2025 - 11:49pm
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We have translated a CRA interpretations released last week and a further 6 CRA interpretations released in June and May of 2000. Their descriptors and links appear below.

These are additions to our set of 3,262 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
2025-07-16 2024 Ruling 2024-1018811R3 F - RCA, Refundable Tax, Letter of credit Income Tax Act - Section 207.5 - Subsection 207.5(2) an RCA trust’s refundable Pt. XI.3 tax can be refunded through winding it up and replacing it by a new LC trust
2000-06-09 11 May 2000 Internal T.I. 2000-0019097 F - RAP RETRAIT EN JANVIER ANNEE SUIVANTE Income Tax Act - Section 146.01 - Subsection 146.01(2) - Paragraph 146.01(2)(d) additional withdrawal request no longer is required to be made before the end of the taxation year preceding the year of the additional withdrawal
2000-05-26 12 May 2000 External T.I. 1999-0008685 F - QUOTA DE LAIT Income Tax Act - Section 85 - Subsection 85(1) can treat fungible transferred property as consisting of two portions, one eligible for the CGD, so that separate agreed amounts made
Income Tax Act - Section 110.6 - Subsection 110.6(2) CGD could be claimed on portion of milk quota eligible as qualified farm property, with s. 85(2) election made to avoid other gain
24 May 2000 External T.I. 2000-0012785 F - INCENDIE MAJEUR CONSEQUENCES Income Tax Act - Section 248 - Subsection 248(1) - Disposition disposition for nil proceeds on property’s destruction without compensation
12 May 2000 External T.I. 1999-0004715 F - PRET A UN EMPLOYE Income Tax Act - Section 6 - Subsection 6(15) no inclusion of principal of loan from employer in employee’s income prior to any forgiveness (including by way of set-off), if the loan is a bona fide loan
2000-05-12 12 April 2000 Income Tax Severed Letter 2000-0010106 F - POMPIERS VOLONTAIRES Income Tax Act - Section 81 - Subsection 81(4) - Paragraph 81(4)(a) meaning of “volunteer” fire fighter
26 April 2000 Income Tax Severed Letter 2000-0017386 F - DOMMAGES-ENTENTE HORS COUR Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance non-taxable damages for harassment