We have translated 6 more CRA interpretations
29 December 2025 - 11:21pm
We have translated a further 6 CRA interpretations released in December of 1999. Their descriptors and links appear below.
These are additions to our set of 3,412 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 26 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 |
|---|---|---|---|
| 1999-12-24 | 14 July 1999 Internal T.I. 9913170 F - APPLICATION 20(4) | Income Tax Act - Section 20 - Subsection 20(4) | no s. 20(4) deduction for payment made on a guarantee of an assumed mortgage (being a novated mortgage) given at the time of sale of the building |
| 16 September 1999 External T.I. 9913250 F - AVANTAGE À UN ACTIONNAIRE | Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Income-Producing Purpose | asset purification expenses incurred for business reasons of the corporation should satisfy the s. 18(1)(a) test | |
| Income Tax Act - Section 15 - Subsection 15(1) | expenses reasonably incurred for business reasons relating to the corporation are disregarded for s. 15(1) purposes | ||
| 26 October 1999 Internal T.I. 9913270 F - BOISE-ENTREPRISE OU PLACEMENT | Income Tax Act - Section 248 - Subsection 248(1) - Farming | woodlot operation can be farming if its main purposes is not logging | |
| 26 October 1999 Internal T.I. 9913280 F - PERTE EN CAPITAL VS PTPE | Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) - Subparagraph 39(1)(c)(ii) | s. 111(4)(d) loss cannot be a BIL under s.329(1)(c)(ii) (but might be under 39(1)(c)(i)) | |
| 28 October 1999 Internal T.I. 9913290 F - APPLICATION DE LA LOI | Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | “anything” is comparable to “property” | |
| 26 October 1999 Internal T.I. 9913300 F - CADEAU BOISSON, VOYAGE BATEAU | Income Tax Act - Section 67.1 - Subsection 67.1(1) | limitation applies to an expense for the purchase of bottles of beverages that will be given to customers | |
| Income Tax Act - Section 67.1 - Subsection 67.1(4) - Paragraph 67.1(4)(a) | s. 67.1(4) does not extend to boats (e.g., cruise ships) since a significant amount paid for the trip might relate to food, beverages and entertainment |