We have translated 5 more CRA interpretations
23 March 2026 - 11:35pm
Email this ContentWe have translated a further 5 CRA interpretations released in August and July of 1999. Their descriptors and links appear below.
These are additions to our set of 3,513 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 |
|---|---|---|---|
| 1999-08-06 | 30 June 1999 Internal T.I. 9911197 F - ABANDON D'UN CAAF BSF CHICOUTIMI | Income Tax Act - Section 13 - Subsection 13(21) - Timber Resource Property - Paragraph (a) - Subparagraph (a)(ii) | TSFMA was a timber resource property notwithstanding that it was non-transferable |
| Income Tax Act - Section 68 | sale proceeds were re-allocable under s. 68 to a timber licence notwithstanding no amount allocated to it in the arm’s length sale agreement and its non-transferability | ||
| Income Tax Act - Section 13 - Subsection 13(21) - Proceeds of Disposition | sale price could be allocated in part to timber permit of the vendor, even though that permit was extinguished rather than transferred on the sale | ||
| Income Tax Act - Section 248 - Subsection 248(1) - Disposition | extinguishment of timber permit on the sale of a business constituted its disposition | ||
| Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) | sale price received as inducement to surrender a timber permit would be income under s. 12(1)(x), if not proceeds of a timber resource property | ||
| Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(b) | must be a person to whom the disposition was made | ||
| 1999-07-23 | 15 July 1999 External T.I. 9819025 F - SOCIETES ASSOCIEES | Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(d) | a corporation deemed by s. 256(1.2)(d) to be owned 51% and 49% by 2 individuals was associated with a corporation each owned directly by them as to 42% each |
| Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(b) - Subparagraph 256(1.2)(b)(ii) | two individuals deemed to own 51% and 49% of a CCPC’s shares were a controlling group under s. 256(1.2)(c) notwithstanding control by one individual alone | ||
| 13 July 1999 External T.I. 9901535 F - PERTE EN CAPITAL - REPUTE NULLE | Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | s. 40(2)(g)(ii) not satisfied on non-interest-bearing loan made to a sister corp | |
| 15 July 1999 External T.I. 9911175 F - EMPLOYÉ - ACTIONNAIRE UNIQUE -207.6(2) | Income Tax Act - Section 207.6 - Subsection 207.6(2) | an employee being the sole shareholder of the employer is insufficient to render s. 207.6(2) inapplicable | |
| 15 July 1999 External T.I. 9916165 F - RAP - VENTE DE LA PROPRIÉTÉ ACQUISE | Income Tax Act - Section 146.01 - Subsection 146.01(3) | no requirement to repay the RRSP or include the HBP balance in income when the qualifying home has been sold |