We have translated 7 more CRA interpretations

5 November 2025 - 12:00am
Email this ContentEmail this Content

We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in January of 2000. Their descriptors and links appear below.

These are additions to our set of 3,361 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 ½ 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
2025-10-29 19 August 2025 External T.I. 2025-1066571E5 F - Distribution of settlement monies to First Nation Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(c) Indian band council is always a s. 149(1)(c) exempt municipality
Income Tax Act - Section 3 - Paragraph 3(a) distribution of land claims settlement amount by Indian band council to its members (including non-Indians) would not constitute income from a source
Income Tax Act - Section 104 - Subsection 104(13) land compensation received by a trust formed an Indian band council would be treated as a capital distribution when distributed
2000-01-07 22 December 1999 External T.I. 9905145 F - ÉTABLISSEMENT STABLE AU CANADA-MALAISIE Treaties - Income Tax Conventions - Article 5 Canadian parent that facilitated sales of its Malay sub could be a dependent agent
21 December 1999 External T.I. 9909645 F - PARTAGE TERRAINS, IMMEUBLE Income Tax Act - Section 248 - Subsection 248(21) - Paragraph 248(21)(c)) properties must have been subdivided in contemplation of the partition
22 December 1999 External T.I. 9912615 F - PROGRAMME D'INVALIDITE DE LONGUE DUREE Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(f) where employer pays the premiums but treats them as salary, the plan qualifies as an employee-pay-all plan; similarly if the premiums paid are taxable benefits
22 September 1999 Income Tax Severed Letter 9920910 F - LLC - DÉDUCTIBILITÉ DES INTÉRÊTS Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) treatment of interest on money borrowed to acquire LLC units turns on whether they are common or preferred shares
23 December 1999 External T.I. 9923785 F - BIENS AGRICOLES ADMISSIBLES Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(a) no disposition when switch from farming to rental use
22 December 1999 External T.I. 9929685 F - DEFINITION FIDUCIE PERSONNELLE Income Tax Act - Section 108 - Subsection 108(7) - Paragraph 108(7)(b) contributions to inter vivos trust by settlor and his wife and son did not cause it to cease to be a personal trust