We have translated 6 more CRA interpretations

24 March 2025 - 11:12pm
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We have translated a further 6 CRA interpretations released in December and November of 2000. Their descriptors and links appear below.

These are additions to our set of 3,145 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 1/3 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
2000-12-08 16 November 2000 Internal T.I. 2000-0035067 F - ALLOCATION DE RETRAITE Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance damages received for terminated bonus arrangement and stock option plan were a retiring allowance
Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) damages received for terminated stock option plan were a retiring allowance rather than taxable under s. 7(1)(b)
28 September 2000 Internal T.I. 2000-0041017 F - ALLOCATION POUR LOGEMENT Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) allowance to cover increased housing costs was taxable
Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) - Subparagraph 6(6)(a)(i) stay of over 2 years was not “temporary”
1 November 2000 Internal T.I. 2000-0043847 F - Distribution par fiducie non résidente
applied in 2003-0013677

 Income Tax Act - 101-110 - Section 104 - Subsection 104(13) distribution of taxable capital gain from non-resident trust was not an exempted “distribution of capital” under s. 104(3)(c)(ii)
3 November 2000 Internal T.I. 2000-0049127 F - CONJOINT DE FAIT DECEDE-CHOIX Income Tax Act - Section 248 - Subsection 248(1) - Common-Law Partner an individual’s common–law partner election could be made by his executor
Income Tax Act - Section 248 - Subsection 248(1) - Person a person can make an election through his executor
Income Tax Act - Section 85 - Subsection 85(1) election by a person can be made by his executor
2000-11-24 16 November 2000 External T.I. 2000-0035815 F - OPTION D'ACHAT D'ACTION General Concepts - Effective Date CCRA could not accommodate re-doing the exercise of stock options
15 November 2000 External T.I. 2000-0041165 F - Action admissible de petite entreprise Income Tax Act - 101-110 - Section 104 - Subsection 104(21.2) - Paragraph 104(21.2)(b) beneficiary is deemed to have disposed of the QSBCS