We have translated 6 more CRA interpretations

17 March 2026 - 11:42pm
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We have translated a CRA interpretation released last week and a further 5 CRA interpretations released in August of 1999. Their descriptors and links appear below.

These are additions to our set of 3,508 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 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
2026-03-11 22 August 2025 External T.I. 2021-0904251E5 F - Taxation of interest from French tax-free accounts Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) French tax-advantaged accounts were subject to taxation to a Cdn resident
Income Tax Act - Section 233.7 the 1st-time s. 233.7 exemption from filing a T1135 can be used only once
1999-08-20 16 July 1999 External T.I. 9916205 F - FRAIS JUDICIAIRES - ALLOCATON DE RETRAITE Income Tax Act - Section 60 - Paragraph 60(o.1) accounting fees might qualify - but not where incurred to calculate the amount of a settlement
1999-08-06 17 September 1998 External T.I. 9817625 F - DÉDUCTIBILITÉ DES INTÉRÊTS Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) receipt of PUC distribution for personal purposes does not reduce deductible interest if the shares remain as a source of income
3 August 1999 External T.I. 9820065 F - FIDUCIE ASPECT DIVERS Income Tax Act - Section 104 - Subsection 104(18) must not be any discretion as to the capitalization of the income
Income Tax Act - Section 73 - Subsection 73(5) quaere whether s. 73(5) could apply to farm property transfer to a child trust
Income Tax Act - Section 108 - Subsection 108(1) - Testamentary Trust testamentary trust cannot arise from an inter vivos trust with multiple beneficiaries
16 July 1999 External T.I. 9821295 F - RÉCUPÉRATION D'AMORTISSEMENT Income Tax Act - Section 111 - Subsection 111(5) - Paragraph 111(5)(a) - Subparagraph 111(5)(a)(ii) recapture is from the same business in which the depreciable property was used
Income Tax Act - Section 13 - Subsection 13(1) recapture is income from the business in which that asset was used
7 July 1999 Internal T.I. 9905067 F - DÉDUCTION POUR IMPÔT ÉTRANGER Income Tax Act - Section 126 - Subsection 126(1) - Paragraph 126(1)(a) maximum credit computed on a source-by-source basis