We have translated 7 more CRA interpretations

We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in December of 1999. Their descriptors and links appear below.

These are additions to our set of 3,425 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
1999-12-10 5 November 1999 Internal T.I. 9827587 F - DÉDUCTION POUR IMPÔTS ÉTRANGERS Treaties - Income Tax Conventions - Article 24 Art. XXIV(5)(b) of the Canada-U.S. Tax Convention, given that Art. XXIV(5)(b) applies to computing a tax credit rather than income from property
Income Tax Act - Section 20 - Subsection 20(11) s. 20(11) deduction available to U.S. citizen residing in Canada
18 October 1999 Internal T.I. 9905377 F - ALLOCATION FRAIS DE DEPLACEMENT Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) if per kilometre allowance is unreasonable, total allowance is included in income
26 October 1999 Internal T.I. 9913080 F - EXPROPRIATION Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition - Paragraph (d) costs of moving equipment assimilated to proceeds in respect of expropriation of plant
27 July 1999 Internal T.I. 9913490 F - LOCATION- MONTANT REÇU- JUGEMENT Income Tax Act - Section 9 - Compensation Payments amount received for a release could constitute proceeds of disposition of a right
27 September 1999 Internal T.I. 9916367 F - REMISE DE DETTE/PRET ETUDIANT Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(n) partial loan repayments where students achieved their degrees were prizes for achievement
Income Tax Act - Section 80 - Subsection 80(1) - Forgiven Amount partial repayment of loans under a Quebec government program did not represent loan forgiveness (the lenders themselves did not forgive the loans)
8 June 1999 APFF Roundtable Q. 51, 9913160 F - PAIEMENT INCITATIF À LA LOCATION Income Tax Act - Section 9 - Timing Canderel indicates that the onus is on CCRA to demonstrate that its income computation method provides a more accurate picture/ those in identical fact situations to Canderel can currently deduct their unamortized TIP balance