We have translated 5 more CRA interpretations

23 June 2026 - 11:36pm
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We have translated a further 5 CRA interpretations released in April of 1999. Their descriptors and links appear below.

These are additions to our set of 3,595 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
1999-04-16 28 January 1998 External T.I. 9722275 F - CONVENTION CANADA-IRLANDE Treaties - Income Tax Conventions - Article 22 withholding rate on s. 212(1)(l) lump sum payment out of an RRSP reduced to 15% under Other Income article of 1966 Canada-Ireland treaty
25 March 1999 External T.I. 9805975 F - 15(1.1) STOCK DIVIDEND AFTER AN ESTATE FREEZE Income Tax Act - Section 15 - Subsection 15(1.1) s. 15(1.1) not engaged if stock dividend paid proportionately to all shareholders
30 March 1999 External T.I. 9822845 F - PENSION ALIMENTAIRE Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day judicial confirmation of support obligation and numerical correction did not give rise to a commencement day
27 October 1998 External T.I. 9824750 F - KNOW-HOW Income Tax Act - Section 248 - Subsection 248(1) - Property know-how not having IP statutory protection is not “property” – but can be transferred as part of goodwill
Income Tax Act - Section 85 - Subsection 85(1.1) know-how not constituting statutorily-protected IP is not “eligible property” unless transferred as part of goodwill
26 March 1999 Internal T.I. 9903097 F - BFT- REDEVANCES - COUT DE LOCATION Income Tax Regulations - Regulation 5202 - Cost of Manufacturing and Processing Capital royalties paid for secret formulae could be “essential and integral to the manufacturing activity”