We have translated 8 more CRA severed letters
11 August 2025 - 11:40pm
Email this ContentWe have translated a CRA interpretation released last week, a ruling released the previous week and a further 6 CRA interpretations released in April of 2000. Their descriptors and links appear below.
These are additions to our set of 3,284 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 |
|---|---|---|---|
| 2025-08-06 | 6 May 2025 External T.I. 2024-1010641E5 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) | the retention of Opco’s real estate in the parent’s Realtyco after a sale of Opco to the child’s Holdco does not render Realtyco a relevant group entity |
| 2025-07-30 | 2024 Ruling 2024-1027631R3 F - Post-mortem planning - Pipeline | Income Tax Act - Section 84 - Subsection 84(2) | classical 24-month pipeline transaction for an investments company whose portfolio had performed poorly |
| 2000-04-28 | 13 April 2000 Internal T.I. 2000-0005737 F - IMPOSITION DES RISTOURNES | Income Tax Act - Section 135 - Subsection 135(4) - Allocation in Proportion to Patronage | insufficient information to determine whether allocations in proportion to patronage, or volume rebates |
| Income Tax Act - Section 9 - Timing | year end rebate amounts, if not allocations in proportion to patronage, were not includible at that time in s. 9 income as the conditions precedent for their payment had not yet been met | ||
| 10 February 2000 Internal T.I. 1999-0014267 F - PRESCRIPTION | Income Tax Act - Section 152 - Subsection 152(4.01) - Paragraph 152(4.01)(a) - Subparagraph 152(4.01)((a)(i) | misrepresentation re underreported income could not be used as basis for reassessing expenses for which there had been no misrepresentation of fact | |
| 2000-04-14 | 5 April 2000 External T.I. 1999-0004235 F - PERTE AU TITRE D'UN PLACEMENT D'ENTREPRISE | Income Tax Act - Section 39 - Subsection 39(12) | s. 39(12) applied to debts acquired by subrogation by paying guaranteed debts seriatim on due dates provided that the guaranteed corp met the SBC test on the first such guarantee payment |
| 31 March 2000 External T.I. 1999-0008715 F - PROPOSE DE LA LOI - XXXXXXXXXX | Income Tax Act - Section 120.4 - Subsection 120.4(1) - Split Income - Paragraph (c) - Subparagraph (c)(ii) - Clause (c)(ii)(C) | split income to minor child beneficiary of trust partner in partnership providing admin services to father’s professional partnership | |
| 18 January 2000 Income Tax Severed Letter 9932456 F - MOT PAYABLE BIEN MEUBLE LÉGUÉ UNIVERSEL | Income Tax Act - Section 104 - Subsection 104(24) | income of Quebec estate was not payable to the residuary beneficiary unless it was generated after estate admin was completed | |
| Income Tax Act - Section 152 - Subsection 152(4.2) | CCRA could reassess estate statute-barred years to allow deduction under ss. 104(6) and (24) for income that became payable after estate administration was complete | ||
| 6 April 2000 External T.I. 2000-0009515 F - Choix 1103(1) et Immeubles locatifs | Income Tax Regulations - Regulation 1103 - Subsection 1103(1) | corporation holding and managing rental properties is carrying on a business |