We have translated 7 more CRA interpretations

3 December 2025 - 8:50am
Email this ContentEmail this Content

We have translated a CRA interpretation released last week and a further 6 CRA interpretations released in January of 2000 and December of 1999. Their descriptors and links appear below.

These are additions to our set of 3,387 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 26 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
2000-01-07 7 October 1999 Internal T.I. 9920970 F - RÉPARTITION DE BIENS Income Tax Act - Section 159 - Subsection 159(3) interim distributions before clearance certificate are permitted, but at the executor’s risk
1999-12-24 1 December 1999 External T.I. 9902255 F - PROGRAMMME ALLOCATION-LOGEMENT Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(u) monthly allowances under the Quebec Shelter Allowance Programs came within s. 56(1)(u)
1 December 1999 External T.I. 9908225 F - BIEN AMORTISSABLE TRANS. AU CONJOINT Income Tax Act - Section 13 - Subsection 13(7) - Paragraph 13(7)(e) capital cost maintained at historical amount on spousal transfer notwithstanding s. 119.6(19) step-up
7 December 1999 External T.I. 9924335 F - ACTIVITÉS DE FABRICATION ET TRANSFORMATION Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits each associated corporation in the production chain could treat its transformative activities for sale to the next entity as qualifying/ Crown Tire generally preferred to Stowe-Woodward
Income Tax Regulations - Regulation 5202 - Cost of Labour work normally done by contractors cannot qualify as cost of labour
1 December 1999 External T.I. 9927575 F - RENONCIATION A UN DIVIDENDE Income Tax Act - Section 80 - Subsection 80(1) - Commercial Debt Obligation dividend waiver does not entail forgiveness of a commercial debt obligation
29 November 1999 External T.I. 9928805 F - BONI VERSE D'UN REER OUR UN FEER Income Tax Act - Section 146 - Subsection 146(8) bonus on stock-market linked debt would not be a benefit to the annuitant
Income Tax Act - Section 146 - Subsection 146(1) - Premium bonus on stock-market linked debt would not be a premium
Income Tax Act - Section 146.3 - Subsection 146.3(3) - Paragraph 146.3(3)(b) bonus on stock-market linked debt would not be a gift