We have translated 8 more CRA interpretations

29 April 2025 - 3:50am
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We have translated two CRA interpretations released last week and a further 6 CRA interpretations released in September of 2000. Their descriptors and links appear below.

These are additions to our set of 3,182 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 ½ 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
2025-04-23 4 January 2022 External T.I. 2016-0644861E5 F - Travail de nature temporaire Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) - Subparagraph 6(1)(a)(i) the "duties … of a temporary nature" condition is tested on a site-by-site basis
28 March 2025 External T.I. 2016-0662951E5 F - Alinéa b) de la définition d’action admissible de Income Tax Act - Section 110.6 - Subsection 110.6(1) - Qualified Small Business Corporation Share - Paragraph (b) settling QSBCS shares on a personal trust with related beneficiaries before a sale of those shares 6 months’ later would not cause QSBCS status to be lost
Income Tax Act - Section 110.6 - Subsection 110.6(14) - Paragraph 110.6(14)(f) settling QSBCS shares on a personal trust whose beneficiaries were related as required by s. 110.6(14)(c)(ii) permitted a sale thereafter without loss of QSBCS status
2000-09-15 29 August 2000 Internal T.I. 2000-0023187 F - Société privée sous contrôle canadien Income Tax Act - Section 125 - Subsection 125(7) - Canadian-Controlled Private Corporation ultimate control of Opco was held by Pubco through an indirect wholly-owned subsidiary that was the general partner of an LP holding 2/3 of Opco’s voting shares
Income Tax Act - Section 251 - Subsection 251(2) - Paragraph 251(2)(b) - Subparagraph 251(2)(b)(i) GP generally controls a corporation whose voting control is held by a limited partnership
16 September 1999 Internal T.I. 9913460 F - CONF. CONS. TECHNIQUES - DOMMAGES Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Damages damages or costs paid to remediate environmental damage caused directly by a company’s operations would generally be deductible
2000-09-01 24 August 2000 External T.I. 2000-0011785 F - CRÉDIT D'IIMPOT FAVORISANT LE DÉVELOPEMENT Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) Quebec tax credit not s. 12(1)(x) income until applied as an instalment or otherwise received
17 August 2000 External T.I. 2000-0025025 F - BIENS ETRANGERS - FONDS MUTUELS DERIVES Income Tax Act - Section 206 - Paragraph 206(1)(i) listing of rulings dealing with foreign property rulings for clone fund MFTs deriving their value from foreign derivatives
17 August 2000 External T.I. 2000-0029745 F - Amortissement-Equipememnt lazer epilation Income Tax Regulations - Regulation 1104 - Subsection 1104(2) - General-Purpose Electronic Data Processing Equipment laser hair removal equipment not general-purpose electronic data processing equipment as user could not modify the computer program underlying the device software
Income Tax Regulations - Schedules - Schedule II - Class 8 laser hair removal equipment included in Class 8 (not general-purpose electronic data processing equipment)
31 August 2000 External T.I. 2000-0035675 F - INSTITUT DE RECHERCHE AGRÉÉ Income Tax Act - Section 37 - Subsection 37(1) - Paragraph 37(1)(a) - Subparagraph 37(1)(a)(ii) - Clause 37(1)(a)(ii)(B) CCRA requires that a hospital research institute be separate from the hospital