We have translated 6 more CRA interpretations
9 June 2025 - 11:44pm
Email this ContentWe have translated a further 6 CRA interpretations released in July of 2000. Their descriptors and links appear below.
These are additions to our set of 3,221 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 |
|---|---|---|---|
| 2000-07-21 | 18 July 2000 External T.I. 2000-0015915 F - PTPE - INTERET PAYE POUR HONORER CAUTION | Income Tax Act - Section 39 - Subsection 39(1) - Paragraph 39(1)(c) - Subparagraph 39(1)(c)(iv) | no BIL on loan from bank to fund guarantee of former SBC’s debt or where subrogated debt of the former SBC arises from voluntary payment of its defaulted debt rather than under guarantee |
| Income Tax Act - Section 40 - Subsection 40(2) - Paragraph 40(2)(g) - Subparagraph 40(2)(g)(ii) | s. 40(2)(g)(ii) applies where loan from bank to fund guarantee of former SBC’s debt or where subrogated debt of the former SBC arises from voluntary payment of its defaulted debt | ||
| 28 June 2000 External T.I. 2000-0020025 F - OSBL - Loi des compagnies, Partie 1A | Income Tax Act - Section 149 - Subsection 149(1) - Paragraph 149(1)(l) | share corporation can potentially qualify as a NPO | |
| 30 June 2000 External T.I. 2000-0026625 F - Exercice financier - 249.1 | Income Tax Act - Section 249.1 - Subsection 249.1(1) - Paragraph 249.1(1)(b) - Subparagraph 249.1(1)(b)(ii) | s. 249.1(1)(b)(ii)(C) does not apply where a member partnership was previously subject to s. 249.1(1)(b)(ii) but was not so subject when it became a member of this partnership | |
| 29 June 2000 External T.I. 2000-0026635 F - APPLICATION 40(3.12) SUITE A 98(6) | Income Tax Act - Section 40 - Subsection 40(3.12) | s. 98(6) permitted accessing of s. 40(3.12) after conversion of LP to general partnership | |
| Income Tax Act - Section 98 - Subsection 98(6) | s. 98(6) applied on conversion of limited partnership to general partnership | ||
| 28 June 2000 External T.I. 2000-0028665 F - QUOTAS DÉTENUS DEPUIS MOINS DE DEUX ANS | Income Tax Act - Section 85 - Subsection 85(1) | taxpayer can order properties (e.g., milk quotas) disposed of on s. 85(1) partial rollover transaction so that the only capital gain is realized on CGD-eligible property | |
| 2000-07-07 | 7 July 2000 External T.I. 2000-0015455 F - Allocation de retraite | Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | the principal shareholder continues as an officer, he is not considered to have retired, even if the corporation's business has been sold |