We have translated 6 more CRA interpretations

30 September 2025 - 11:37pm
Email this ContentEmail this Content

We have translated a further 6 CRA interpretations released in February of 2000. Their descriptors and links appear below.

These are additions to our set of 3,330 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 25 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
2000-02-18 22 December 1999 Internal T.I. 9921477 F - CREDIT EQUIV. POUR PERS. ENTIRE. A CHARGE Income Tax Act - Section 118 - Subsection 118(1) - Paragraph 118(1)(b) secondary caregiver responsibility can entitle to the credit
2 November 1999 Internal T.I. 9923277 F - PARTICIPATION INDIVISE - TEST POUR 1100(14) Income Tax Regulations - Regulation 1100 - Subsection 1100(14) qualitative and quantitative test applied re the use test
30 November 1999 Internal T.I. 9924657 F - BFT Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits uniforms were manufactured for sale notwithstanding that customer supplied the fabric
Income Tax Regulations - Regulation 5202 - Cost of Manufacturing and Processing Labour amounts paid to subcontractors were excluded
2000-02-04 20 January 2000 External T.I. 9918035 F - SOCIETE DE PERSONNES RATTACHEE Income Tax Act - Section 15 - Subsection 15(2.1) partnership between 5 equal individual partners likely would be connected with such individuals qua shareholders of their respective corporations that formed a second partnership
Income Tax Act - Section 251 - Subsection 251(1) - Paragraph 251(1)(c) partnership between 5 equal individual partners likely did not deal at arm’s length with such individuals qua shareholders of their respective corporations that formed a second partnership
13 January 2000 Internal T.I. 9931087 F - ENFANT MINEUR - ACHAT D'UNE RENTE Income Tax Act - Section 60 - Paragraph 60(l) - Subparagraph 60(l)(ii) - Clause 60(l)(ii)(B) example of 14-year old receiving 48-payment monthly annuity
24 January 2000 External T.I. 1999-0008275 F - APPLICATION DU PARAGRAPHE 75(2) Income Tax Act - Section 75 - Subsection 75(2) inclusion of settlor as one of three trustees would not by itself engage s. 75(2)/ s. 75(2) necessarily applies if the settlor is the sole trustee