We have translated 5 more CRA interpretations

4 August 2026 - 11:43pm
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We have translated a further 5 CRA interpretations released in March and February of 1999, and have also connected (and summarized) three French interpretations to the CRA translation found in another document. Their descriptors and links appear below.

These are additions to our set of 3,631 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 16 February 1999 Internal T.I. 9901667 F - PATIE I.3 Income Tax Act - Section 181.3 - Subsection 181.3(1) - Paragraph 181.3(1)(a) supplies were “tangible property,” i.e., had a physical existence
Income Tax Act - Section 181.3 - Subsection 181.3(3) - Paragraph 181.3(3)(a) deferred revenue is not a liability
Income Tax Act - Section 181 - Subsection 181(1) - Reserves provision for future retiring allowances was a contingent liability included in reserves
1999-03-19 26 February 1999 External T.I. 9807395 F - DÉBUT EXPLOITATION ENTREPRISE ACTIVE Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs seniors' home business might commence with construction of the home
Income Tax Act - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (c) - Subparagraph (c)(i) building that is constructed for use in a business that is in fact carried on may be used in business during construction
1999-02-19 8 February 1999 External T.I. 9820355 F - SOCIÉTÉS ASSOCIÉES Income Tax Act - Section 89 - Subsection 89(1) - Private Corporation de jure control of corporation through the closely-held general partner of the LP holding its shares rendered it a private corporation
Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation GP of LP generally has de facto control of a corporation held by the LP
Income Tax Act - Section 256 - Subsection 256(1.2) - Paragraph 256(1.2)(e) application of s. 256(1.2)(e) to 99% limited partner caused the corporation held by the LP to be associated with any other corp controlled by that limited partner
Income Tax Act - Section 251 - Subsection 251(5) - Paragraph 251(5)(b) - Subparagraph 251(5)(b)(i) employee stock options did not give employees control since none of them individually had options on over 50% of the shares
Income Tax Act - Section 256 - Subsection 256(1.4) - Paragraph 256(1.4)(a) 256(1.4)(a) rendered employees a deemed control group
20 November 1998 Internal T.I. 9827357 F - PENSION ALIMENTAIRE ENFANT DATE D'EXÉCUTION Income Tax Act - Section 56.1 - Subsection 56.1(4) - Commencement Day no commencement day when changes to child support were not pursuant to any change in the judicial order
1999-02-05 28 January 1999 External T.I. 9900095 F - RÉGIME DE RETRAITE EXCÉDENTAIRE Income Tax Act - Section 248 - Subsection 248(1) - Salary Deferral Arrangement whether a plan is a SERP turns on its terms and the parties’ intentions