We have translated 5 more CRA interpretations

We have translated a further 5 CRA interpretations released in May of 1999. Their descriptors and links appear below.

These are additions to our set of 3,563 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 27 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
1999-05-28 6 January 1999 Internal T.I. 9816727 F - METHODE DE REMPLACEMENT- MATERIEL CONSOMME Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) - Subparagraph 37(8)(a)(ii) - Clause 37(8)(a)(ii)(B) - Subclause 37(8)(a)(ii)(B)(V) “materials consumed” does not refer to use of equipment
Income Tax Act - Section 127 - Subsection 127(27) overhead costs incurred in constructing engines are not included/ property used for testing purposes and then disposed of, could qualify
10 February 1999 Internal T.I. 9829297 F - SÉCHOIRS A BOIS - AMORTISSEMENT Income Tax Regulations - Schedules - Schedule II - Class 8 - Paragraph 8(c) buildings comprised of cells used to dry wood together with the heating equipment in another building constituted “kilns” used in processing
14 April 1999 Internal T.I. 9831627 F - INTEREACTION 1100(11) ET 13(21.2)E)(III) Income Tax Act - Section 13 - Subsection 13(21.2) - Paragraph 13(21.2)(e) - Subparagraph 13(21.2)(e)(iii) rental property restriction rules do not apply to s. 13(21.2)(e)(iii) property
Income Tax Regulations - Regulation 1100 - Subsection 1100(11) Reg. 1100(11) does not apply to a s. 13(21.2)(e)(iii) property
21 January 1999 Internal T.I. 9900197 F - DÉDOMMAGEMENT PAYÉ À UN LOCATAIRE Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Damages damages paid for having caused tenant disruption from renovations were an addition to building cost if such renovations were capital expenditures
Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(c) interest for damages received for loss of a subtenant was taxable – interest on damages for personal loss and on exemplary damages was non-taxable
Income Tax Act - Section 13 - Subsection 13(21) - Undepreciated Capital Cost - A interest and legal fees incurred re damages paid for having caused tenant disruption from renovations were an addition to building cost if such renovations were capital expenditures
14 April 1999 Internal T.I. 9901637 F - CATEGORIE 41 -LIE A SOI MEME Income Tax Regulations - Schedules - Schedule II - Class 41 - Paragraph (a.1)) - Subparagraph (a.1)(iv) (a.1)(iv) exclusion for NAL acquisition did not apply where the taxpayer acquired the property that it previously had leased
Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) a person does not deal not-at-arm’s-length with itself unless deemed to do so