We have translated 6 more CRA interpretations

13 April 2026 - 11:39pm
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We have translated a CRA interpretation released last week and a further 5 CRA interpretations released in June of 1999. Their descriptors and links appear below.

These are additions to our set of 3,530 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
2026-04-08 14 January 2026 Internal T.I. 2023-0990701I7 - Application of Reg. 5907(8)(a) in acquisition year Income Tax Regulations - Regulation 5907 - Subsection 5907(8) Reg. 5907(8)(a) is limited to mergers of what are already foreign affiliates of a corporation resident in Canada
1999-06-25 16 June 1999 External T.I. 9824635 F - TRANSFERT DE BIEN À UNE SOCIÉTÉ Income Tax Act - Section 74.4 - Subsection 74.4(2) main purpose test can encompass an unborn child or a future spouse
21 June 1999 External T.I. 9829395 F - PRODUIT POLICE ASSURANCE INVALIDITE Income Tax Act - Section 70 - Subsection 70(5.3) no equivalent of s. 70(5.3) for disability proceeds
15 June 1999 External T.I. 9902745 F - COOPÉRATIVE DE TRAVAILLEURS Income Tax Act - Section 136 - Subsection 136(2) workers’ cooperative qualifies as a cooperative corporation
Income Tax Act - Section 15 - Subsection 15(2.4) - Paragraph 15(2.4)(c) exception in paragraph 15(2.4)(c) could apply to a loan made to acquire shares (units) of a cooperative
21 June 1999 External T.I. 9909465 F - CATÉGORIE 6 Income Tax Regulations - Schedules - Schedule II - Class 6 - Paragraph (a) - Subparagraph (a)(vii) “footings” has its construction-industry meaning
16 June 1999 External T.I. 9916555 F - REEE - CONTENU ÉTRANGER Income Tax Act - Section 206 RESP could hold foreign property