We have translated 7 more CRA interpretations

25 November 2025 - 11:47pm
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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 3,380 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
2025-11-19 10 September 2025 External T.I. 2025-1070171E5 F - Disposition of a right to receive bitcoins Income Tax Act - Section 9 - Capital Gain vs. Profit - Cryptocurrency lack of income on bitcoins suggested that they might be acquired on income account
Income Tax Act - Section 54 - Adjusted Cost Base property acquired on income account does not have an ACB
2000-01-07 5 November 1999 Internal T.I. 9907667 F - PROGRAMME DE FORMATION ADMISSIBLE Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program - Paragraph (a) employment insurance, and EI educational assistance, were not excluded and excluded, respectively
12 October 1999 Internal T.I. 9912347 F - FORFAITAIRE FIN DE LA LOCATION Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Incurring of Expense excess kilometre charges at conclusion of lease were not deductible until then
Income Tax Act - Section 67.3 - Paragraph 67.3(c) excess kilometre charges at conclusion of lease would have same effect under s. 67.3 formula as if allocated evenly over the lease
29 October 1999 Internal T.I. 9915337 F - PROGRAMME DE FORMATION ADMISSIBLE Income Tax Act - Section 118.6 - Subsection 118.6(1) - Qualifying Educational Program - Paragraph (a) EI training allowances, but not EI benefits, were excluded
9 November 1999 Internal T.I. 9917947 F - RESIDENCE DES MEMBRES DU CLERGE Income Tax Act - Section 8 - Subsection 8(1) - Paragraph 8(1)(c) priest who was a chaplain satisfied the requirements
2 September 1999 APFF Roundtable Q. 14, 9921000 F - MOMENT DE DETERMINATION DU REVENU PROTEGE Income Tax Act - Section 55 - Subsection 55(1) - Safe-Income Determination Time presence of unrelated minority shareholder at time of drop-down transaction triggered a s. 55(3)(a)(ii) increase in direct interest and thus a safe-income determination time
17 August 1999 APFF Roundtable Q. 20, 9921060 F - SOCIÉTÉ BÉNÉFICIAIRE D'UNE FIDUCIE Income Tax Act - Section 186 - Subsection 186(4) - Paragraph 186(4)(a) addition of s. 251(1)(b) caused a corporate beneficiary of personal trust to be related under ss. 186(2) and 186(4)(a) to dividend payer respecting dividend designated to it under s. 104(19)
Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(b) addition of s. 251(1)(b) caused a corporate beneficiary of personal trust to be related under ss. 186(2) and 186(4)(a) to a trust-controlled corporation paying a dividend to the trust
Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (a) no CDA addition re dividend designated to CCPC as a taxable capital gain under s. 104(21)
Income Tax Act - Section 55 - Subsection 55(2.1) - Paragraph 55(2.1)(c) s. 104(19) dividend can come out of safe income