We have translated 6 more CRA interpretations

13 October 2025 - 9:02pm
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We have translated a further 6 CRA interpretations released in January of 2000. Their descriptors and links appear below. These are additions to our set of 3,342 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
2000-01-21 10 January 2000 External T.I. 9908665 F - PROGRAMME IMMIGRANT INVESTISSEUR Income Tax Act - Section 248 - Subsection 248(1) - Small Business Corporation an asset pledged as security for a long-term debt of the business is not in itself considered to be used in that business
10 January 2000 External T.I. 9908925 F - FRAIS DE VOYAGE DU CONJOINT Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) reimbursement of family’s travel expenses when professor is on continuing education leave, is a taxable benefit
10 January 2000 External T.I. 9917635 F - FRAIS JURIDIQUES-PENSION ALIMENTAIRE Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees legal fees to modify rather than to enforce support were not deductible
21 December 1999 External T.I. 9928755 F - INDEMNITE DE DEPART-DECES Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance retiring allowance paid to beneficiary of deceased employee is a death benefit
Income Tax Act - Section 248 - Subsection 248(1) - Death Benefit retiring allowance paid after death was death benefit
6 January 2000 External T.I. 9929675 F - FUSION - CAPITAL VERSÉ ET PBR Income Tax Act - Section 87 - Subsection 87(4) transfer of individual’s directly held shares to his Holdco at a high elected amount followed by the 2 corporations’ amalgamation reflected in stepped-up ACB of Amalco shares
20 December 1999 External T.I. 9930245 F - COOPERATIVE DE CREDIT ET CAPITAL ACTIONS Income Tax Act - Section 248 - Subsection 248(1) - Share no difference between French and English definition of “share”/ interest in federation fund not a “share”