We have translated 7 more CRA severed letters

20 May 2025 - 11:44pm
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We have translated a CRA ruling released last week and a further 6 CRA interpretations released in August of 2000. Their descriptors and links appear below.

These are additions to our set of 3,202 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
2025-05-14 2024 Ruling 2023-0970691R3 F - Part VI.1 of the Income Tax Act Income Tax Act - Section 248 - Subsection 248(1) - Short-Term Preferred Share - Paragraph (a) - Subparagraph (a)(i) Part VI.1 tax could apply to an agreement to repurchase common shares for their current FMV, if their FMV declines by the closing time
Income Tax Act - Section 248 - Subsection 248(1) - Taxable Preferred Share - Paragraph (f) TPS definition did not apply to common share repurchase agreement where repurchase price in fact did not exceed FMV at closing time
2000-08-18 24 May 2000 Internal T.I. 2000-0014047 F - Société publique - titres au comptoir Income Tax Act - Section 89 - Subsection 89(1) - Public Corporation - Paragraph (a) shares which trade over the counter do not qualify as listed on a stock exchange
2 June 2000 Internal T.I. 2000-0016087 F - SECTION DE LA LOI128(2)E Income Tax Act - Section 128 - Subsection 128(2) - Paragraph 128(2)(g) - Subparagraph 128(2)(g)(i) pre-discharge NCLs cannot be carried forward to taxation years after the discharge
13 June 2000 Internal T.I. 2000-0027577 F - CORRECTION PARTAGE VS SOULTE
s. 12(1)(x)(iv) application confirmed in 2000-0046180 F

 Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(x) - Subparagraph 12(1)(x)(iv) amounts under a settlement agreement compensating for additional interest on an excessive mortgage assumption amount was income under s. 12(1)(x)(iv) rather than proceeds
2000-08-04 20 July 2000 External T.I. 1999-0008445 F - Produit de Disposition
Position on Question 1 overruled by 2001-0091655 F

 Income Tax Act - Section 85.1 - Subsection 85.1(1) - Paragraph 85.1(1)(a) rules in s. 85.1(1)(a) applied to vendor RRSP
Income Tax Act - Section 85.1 - Subsection 85.1(1) - Paragraph 85.1(1)(b) cost to purchaser is determined under s. 85.1(1)(b) irrespective of gain elected to be recognized by vendor
25 July 2000 External T.I. 2000-0032715 F - Alinéa g) de catégorie 16 annexe II Regl. Income Tax Regulations - Schedules - Schedule II - Class 16 - Paragraph 16(g) truck could qualify notwithstanding that used to transport the taxpayer’s own retail sales at no separate charge
18 July 2000 External T.I. 2000-0033395 F - CONJOINT DE FAIT DE MEME SEXE Income Tax Act - Section 146.01 - Subsection 146.01(1) - Regular Eligible Amount effective date of expansion of common-law partners to include same-sex couples
Income Tax Act - Section 248 - Subsection 248(1) - Common-Law Partner effective date of expansion of common-law partners to include same-sex couples applied only after 2001 unless joint election made