We have translated 7 more CRA severed letters

16 February 2026 - 11:22pm
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We have translated a further CRA ruling issued several weeks ago and 6 CRA interpretations released in November and October of 1999. Their descriptors and links appear below.

These are additions to our set of 3,484 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
2026-01-28 2024 Ruling 2024-1029151R3 F - Hybrid Post-mortem pipeline Income Tax Act - Section 84 - Subsection 84(2) pipeline transaction for transfer of preferred shares of estate in investments company to Newco held by children’s trust (also holding the common shares)
1999-11-26 18 June 1999 Internal T.I. 9830217 F - FRAIS MEDICAUX-AGENCE D'ADOPTION Income Tax Act - Section 118.2 - Subsection 118.2(2) - Paragraph 118.2(2)(a) whether the portion of adoption fees for mandatory medical examination before arrival in Canada qualified
5 October 1999 External T.I. 9922285 F - RAP SENS DU MOT CONJOINT Income Tax Act - Section 146.01 - Subsection 146.01(1) - Regular Eligible Amount - Paragraph (f) ownership of home by separated spouse disqualifies the taxpayer
1999-11-12 12 October 1999 External T.I. 9902655 F - FRAIS DE GARDE D'ENFANTS Income Tax Act - Section 63 - Subsection 63(3) - Child Care Expense fees paid to a school once the child has reached mandatory school age generally are not child care expenses
14 October 1999 External T.I. 9904375 F - INDIEN-REVENU DE PLACEMENTS Other Legislation/Constitution - Federal - Indian Act - Section 87 investment income from on-reserve branch of a financial institution generally is derived from off-reserve income-generating activity
15 October 1999 External T.I. 9908175 F - PERTE EN CAPITAL VS PTPE Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) - Subparagraph 39(1)(c)(ii) a s. 111(4)(d) loss is not deemed to be from a disposition to a person
Income Tax Act - Section 111 - Subsection 111(4) - Paragraph 111(4)(e) s. 111(4)(e) designation could be made within 90 days of denying a s. 111(4)(d) loss as a BIL
Statutory Interpretation - Interpretation/Definition Provisions deeming there to be a disposition does not mean that it is deemed to be to a person
1999-10-29 21 September 1999 External T.I. 9915915 F - CONTRAT DE RENTE ET RPA Income Tax Act - Section 147.4 - Subsection 147.4(1) issuance of an annuity to distribute RPP’s actuarial surplus does not satisfy s. 147.4(1)