We have translated 7 more CRA interpretations

24 February 2025 - 11:59pm
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We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in January of 2001. Their descriptors and links appear below.

These are additions to our set of 3,117 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 24 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
2025-02-19 18 June 2024 Internal T.I. 2024-1006551I7 F - Subsection 143.2(15) and statute-barred year Income Tax Act - Section 143.2 - Subsection 143.2(15) s. 143.2(15) authorized CRA to open-up a statute-barred year to deny the carryback of a loss which it will deny under s. 143.2
2001-01-05 19 December 2000 Internal T.I. 2000-0009277 F - Fosse pour traitement du fumier Income Tax Regulations - Schedules - Schedule II - Class 1 - Paragraph 1(q) manure pit was a Class 1(q) structure
Income Tax Act - Section 30 costs of drainage system for farmer’s manure pit were deductible
14 September 2000 Internal T.I. 2000-0035797 F - ALLOCATION DE SEJOUR Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(iii) representation allowance must cover additional expenses from being posted abroad
Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) - Subparagraph 6(6)(a)(i) purpose of s. 6(6)/ meaning of “temporary” duties and “maintained” re foreign internship
19 December 2000 Internal T.I. 2000-0049197 F - DEDUCTIBILITE DES INTERETS Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) interest on money borrowed to acquire a mutual fund unit or common share that can only yield capital gains is not deductible
15 December 2000 External T.I. 2000-0049645 F - CHANGEMENT PARTIEL D'USAGE RESIDENCE Income Tax Act - Section 45 - Subsection 45(1) - Paragraph 45(1)(c) basement rented out on a cost-recovery basis to husband’s corporation likely did not represent an income-producing use
15 December 2000 Internal T.I. 2000-0052397 F - PRESTATIONS RETROACTIVES DE LA CSST Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(v) worker’s compensation received by the mother as compensation to the child was included in her income on receipt
19 December 2000 Internal T.I. 2000-0054467 F - VALEUR DU DON D'UNE POLICE D'ASSURANCE Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts gift amount of a life insurance policy to be assigned